Hospice Payments Up 2.9%, HOPE Tool Coming

The Centers for Medicare and Medicaid Services (CMS) finalizes the fiscal year (FY) 2025 hospice payment rule. View the complete rule at the Federal Register.

Payment updates

CMS finalizes a market basket update of 3.4% for FY 2025. With the required productivity adjustment of 0.5%, the net update is 2.9%.

See tables 9 and 10 for all finalized payment rates.

The final hospice cap amount for the FY 2025 cap year is $34,465.34. This is derived from the FY 2024 cap amount ($33,494.01) updated by the final FY 2025 hospice payment update of 2.9%.

Table 9: Final FY 2025 Hospice RHC Payment Rates

Code	Description	FY 2024 Payment Rates	SIA Budget Neutrality Factor	Wage Index Standardization Factor	FY 2025 Hospice Payment Update	FY 2025 Payment Rates
651	Routine Home Care (days 1-60)	$218.33	1.0014	0.9984	1.029	$224.62
651	Routine Home Care (days 61+)	$172.35	1.0001	0.9975	1.029	$176.92

Table 10: Final FY 2025 Hospice CHC, IRC, and GIP Payment Rates

Code	Description	FY 2024 Payment Rates	Wage Index Standardization Factor	FY 2025 Hospice Payment Update	FY 2025 Payment Rates
652	Continuous Home Care Full Rate = 24 hours of care.	$1,565.46	1.0048	1.029	$1,618.59 ($67.44 per hour)
655	Inpatient Respite Care	$507.71	0.9930	1.029	$518.78
656	General Inpatient Care	$1,145.31	0.9928	1.029	$1,170.04

Wage index changes

For FY 2025, CMS finalizes the wage index, based on the FY 2025 hospital pre-floor, pre-reclassified wage index for hospital cost reporting periods beginning on or after October 1, 2020, and before October 1, 2021 (FY 2021 cost report data).

CMS adopts the most recent Office of Management and Budget (OMB) statistical area delineations, which may change the hospice wage index for some hospices across the country and Puerto Rico.

Impacted locations are laid out in a series of eight tables in the rule:

• Table 1 — In North Dakota, CMS finalizes rural North Dakota would become a rural area without a hospital from which hospital wage data can be devised. CMS would, therefore, use contiguous core based statistical areas (CBSAs) as a proxy. The final wage index for FY 2025 is 0.8545 for rural North Dakota.

• Table 2 — In Connecticut, CMS finalizes replacing the eight counties with the nine new “planning regions,” per the state’s request. Table 2 reflects the crosswalk.

• Table 3 — Urban counties changing to rural. A total of 53 counties (and county equivalents) currently considered urban would be considered rural beginning in FY 2025.

• Table 4 — Rural counties becoming urban. A total of 54 counties (and county equivalents) currently located in rural areas would be considered located in urban areas beginning in FY 2025.

• Table 5 — Urban areas with a CBSA name or number change. There are 57 changes.

• Table 6 — Urban areas subsumed into another CBSA. There are three counties in this situation.

• Table 7 — Counties changing CBSA. Under the new delineations, some counties would shift between existing and new CBSAs, changing the CBSAs’ constituent makeup. Also, some CBSAs have counties splitting off to become part of or form entirely new labor market areas. There are 73 counties in this situation.

• Table 8 — Transition codes. CMS finalizes beginning in FY 2025, counties with a different wage index value than the CBSA or rural area into which they are designated after the application of the 5% cap will use a wage index transition code. These special codes are five digits in length and begin with “50.” There are 36 counties that will use specific transition codes.

Hospice Quality Reporting Program (HQRP)

HQRP background

The HQRP includes specific reporting requirements for the Hospice Item Set (HIS), administrative data, and Consumer Assessment of Healthcare Providers and Systems (CAHPS®) Hospice Survey. The Consolidated Appropriations Act of 2021 required an increase from 2% to 4% reduction for hospices failing to meet reporting requirements and thresholds. That payment reduction was implemented in the FY 2024 hospice final rule.

CMS says typically, 18% of Medicare-certified hospices are found non-compliant with the HQRP reporting requirements annually and are subject to the payment reduction in a given FY. Many face payment reductions based on failure to meet the reporting threshold of 90%.

New measures

HOPE assessment instrument

CMS finalized the Hospice Outcomes and Patient Evaluation (HOPE) tool in the FY 2020 final hospice rule and will begin collecting the HOPE standardized patient level data October 1, 2025. HOPE will replace the HIS.

The HOPE tool contains demographic, record processing, and patient-level standardized data elements to be collected by all Medicare-certified hospices for all patients over the age of 18, regardless of payer source, to support HQRP quality measures. The data elements represent domains such as administrative, preferences for customary routine activities, active diagnoses, health conditions, medications, and skin conditions.

CMS finalizes HOPE data would be collected for each patient admission at three distinct time points: admission, the hospice update visit (HUV), and discharge.

Currently, CMS requires hospices submit 90% of all required HIS records within 30 days of the event (the patient’s admission or discharge). The 90% threshold applies to all required HIS records, which must be submitted and accepted within the 30-day submission deadline to avoid a payment penalty.

CMS will apply this same 90% threshold to HOPE admission, discharge, and two HUV records. After the HIS is phased out, hospices would need to submit 90% of all required HOPE records to support the quality measures within 30 days of the event or completion date (patient’s admission, discharge, and based on the patient's length of stay up to two HUV timepoints).

Consumer Assessment of Health Care Providers and Systems (CAHPS)

CMS finalizes several changes to the CAHPS program:

• Adding an email invitation to a web survey
• Removing one survey item regarding confusing or contradictory information from the Hospice Team Communication measure
• Replacing the multi-item Getting Hospice Care Training measure with a new, one-item summary measure
• Adding two new items, which will be used to calculate a new Care Preferences measure
• Simplified wording to component items in the Hospice Team Communication, Getting Timely Care, and Treating Family Member with Respect measures
• Removing three nursing home items and an item about moving the family member

Clarification on Conditions of Participation (CoPs), payment requirements

• To add the physician member of the hospice interdisciplinary group as an individual who may review the clinical information for each patient and provide written certification it’s anticipated the patient's life expectancy is six months or less if the illness runs its normal course.
• An update to the medical director and admission to hospice care CoPs to clarify if the medical director is unavailable, the physician designee may review the clinical information and certify the terminal illness.
• Clarifications on the requirements related to the election statement and notice of election (NOE) under the CoPs. CMS indicates these changes are intended to reorganize and more clearly distinguish the separate requirements for the “election statement” and the NOE.

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