NAHC Urges Permanent Medicare Flexibilities for Use of Technology in Hospice

WASHINGTON, D.C. (May 20, 2020)—The National Association for Home Care & Hospice (NAHC) is urging the Centers for Medicare & Medicaid Services (CMS) to establish permanent flexibilities allowing hospices to utilize telecommunications to deliver multi-disciplinary, patient-centered care, and to ensure that such services can be recorded and monitored for their impact on quality of care.

In a letter to CMS Administrator Seema Verma on Friday, May 15, 2020, NAHC President William A. Dombi expressed gratitude for the agency’s numerous actions to ease regulatory burdens on hospice providers during the COVID-19 public health emergency, and recommended CMS take the following steps:

• Clarify that hospice providers are permitted to use telecommunications technology — as appropriate and feasible, and in compliance with applicable HIPAA requirements — to perform service visits as determined by the IDT and as outlined and specified on the plan of care beyond the current public health emergency;
• Fast-track development of modifiers or revenue codes that reflect various types of telecommunications-based visits for use in reporting on hospice claims; and
• Clarify that hospice providers may include telecommunications-based visits as part of visit reporting under Section O of the HIS Discharge record.
• Develop regulations that permanently allow the hospice F2F recertification to be completed using telecommunications technology where feasible and appropriate.

Dombi writes that while “(i)t is too early to make a determination as to when risks associated with the COVID-19 virus will subside…it is widely believed that health care delivery will be altered for the foreseeable future by COVID-19. This will most certainly be the case for services rendered to individuals with serious illness and those that are terminally ill. Given this likelihood, we believe it is an appropriate time to begin discussions around steps that can be taken by CMS to establish permanent Medicare policies related to the ongoing use of telecommunications technology in hospice care. Further, it may be time to set in motion actions that will allow for proper monitoring of utilization of technology-based visits and for assessment of their impact on quality of care outside of the current public health emergency.”

NAHC’s letter acknowledges that in the early days of the COVID emergency, difficulties in accessing patients in their homes, nursing homes, or other congregate living sites due to fear of transmission resulted in  “[m]any hospice providers…[believing]…they needed to discharge patients because they could not adequately address the care needs outlined in the plan of care.”  CMS’ actions clarifying that a variety of telecommunications options are permitted for use in delivering service visits — provided that the visits address patient care needs, meet the goals of care, and are specified on the plan of care.  As a result, hospice providers have found that, “when used appropriately, this mode of care can provide substantial benefits to patients, family members, and hospice staff.”

A copy of the letter is available here.