WASHINGTON—The National Partnership for Healthcare and Hospice Innovation (NPHI) has submitted to the Centers for Medicare & Medicaid Services (CMS) and shared with state Medicaid directors a comment letter urging policymakers and regulators to ensure that individuals receiving hospice and palliative care services are explicitly exempt from Medicaid community engagement requirements during implementation of CMS’s interim final rule (CMS-2454-IFC).
CMS-2454-IFC would implement the statutory Medicaid community engagement requirements established by Congress for certain Medicaid expansion beneficiaries while supporting CMS’s objective of ensuring individuals who are medically unable to meet those requirements retain access to health coverage.
NPHI expressed concern that the rule does not sufficiently address how states should identify and exempt individuals receiving hospice or palliative care services.
“We greatly appreciate CMS’s recognition that individuals who are medically unable to meet community engagement requirements should retain access to Medicaid coverage,” said Tom Koutsoumpas, founder and CEO of NPHI. “However, the rule does not provide sufficient guidance on how states should identify and exempt individuals receiving hospice care or individuals with serious illness who are actively receiving palliative care services. We urge CMS and state Medicaid agencies to provide explicit guidance to ensure these medically vulnerable beneficiaries are appropriately exempt from community engagement requirements.”
NPHI said that hospice and palliative care patients frequently experience significant symptom burden, functional limitations, caregiver dependence and rapidly changing medical circumstances. While many individuals may ultimately qualify for existing exemptions based on disability, medical frailty or other serious health conditions, implementation decisions at both the federal and state levels will determine whether beneficiaries experience unnecessary administrative burdens or interruptions in coverage.
“Implementation matters,” said Ethan McChesney, senior policy director at NPHI. “CMS and state Medicaid agencies should adopt implementation approaches that proactively identify hospice and palliative care patients and ensure they are not inadvertently subjected to community engagement requirements. They can do this by leveraging existing Medicaid eligibility, claims, encounter and provider data can help protect medically vulnerable beneficiaries while minimizing unnecessary administrative burdens for patients, caregivers and providers.”
NPHI’s comment letter outlines several recommendations to help CMS and state Medicaid agencies promote consistent implementation while protecting medically vulnerable beneficiaries.