The U.S. Centers for Medicare & Medicaid Services (CMS) is moving towards the development of health equity quality measures for hospices.
Last year, the agency convened a technical expert panel (TEP) to study the issue, according to language in its 2024 proposed hospice rule. Among the questions the panel has considered is the addition of new measures to the Hospice Quality Reporting Program (HQRP).
To date, CMS has not put forth any specific new measures, but the proposed rule does contain a request for information (RFI) designed to gather data on how hospices approach health equity.
“CMS is trying to figure out where the data needs to be collected from and how to share it with hospices so that they understand how to work with vulnerable populations and best practices about gathering that data,” Katy Barnett, director for home care and hospice operations and policy at LeadingAge, told Hospice News. “I’m assuming that part of that is really leaning into the HOPE tool development and looking at consistency across all post-acute care providers and making sure that we’re tracking the same types of elements.”
The Hospice Outcomes & Patient Evaluation (HOPE) tool is currently in the testing phase. When finalized, CMS expects that this assessment methodology will replace the Hospice Item Set (HIS) measures.
According to CMS, hospices will use the tool to assess patients in real-time based on their interactions rather than through the retrospective chart reviews currently used to comply with HIS requirements.
As with the rest of the health care system, inequities persist among people of color, rural patients and the LGBTQ+ community, among others, including socioeconomic status.
More than 80% of hospice patients are white, according to CMS. Disparities have also been observed in the quality of care for people of color, who often have higher rates of hospice disenrollment.
All told, racial disparities in particular drive up the nation’s health care spend by an estimated $93 billion and result in about $42 billion in lost productivity annually, CMS reported.
The issue of health equity has become a high priority for the agency following President Joe Biden’s Executive Order 13985, “Advancing Racial Equity and Support for Underserved Communities Through the Federal Government.”
‘We are working to advance health equity by designing, implementing, and operationalizing policies and programs that support health for all the people served by our programs, eliminating avoidable differences in health outcomes experienced by people who are disadvantaged or underserved, and providing the care and support that our enrollees need to thrive,” the agency indicated in the proposed rule.
To advance these goals, CMS is seeking information from hospice providers on the following questions:
- What efforts do hospices employ to measure impact on health equity?
- What factors do hospices observe that influence beneficiaries in electing and accessing hospice care?
- What geographical area indices, beyond urban/rural, can CMS use to assess disparities in hospice?
- What information can CMS collect and share to help hospices serve vulnerable and underserved populations and address barriers to access?
- What sociodemographic and SDOH data should be collected and used to effectively evaluate health equity in hospice settings?
- What are feasible and best practice approaches for the capture and analysis of data related to health equity?
- What barriers do hospices face in collecting information on SDOH and race and ethnicity? What is needed to overcome those barriers?
The answers to these questions will help inform CMS’s future work on this issue, according to Katie Wehri, director of home health & hospice regulatory affairs, for the National Association for Home Care & Hospice (NAHC).
“CMS’ first step in improving the information that we have is to get better data so that we can have better measurement and reporting on equity across CMS programs and in policies,” Wehri said in a recent NAHC webinar. “And we have to remember as CMS is looking at health equities or health inequities, they’re thinking about what kind of information they can share with providers, how might this impact payment or the quality reporting program. So CMS is seeking input from providers to help them in some of those decisions.”
The RFI follows up on an earlier request that appeared in the 2023 final rule.
Public comments on the 2023 language led CMS to establish a technical expert panel that spent much of last year working through possible approaches to health equity in hospice.
Among the panel’s top priorities was to assess the validity and feasibility of a potential structural measure for health equity and options for monitoring providers’ progress on related goals. The TEP has also been considering the inclusion of social determinants of health into quality measures and data stratification.
CMS expects to make the TEP’s findings public sometime this year.
“We don’t yet have the results or a report on what that technical expert panel decided or what their final recommendations were. We don’t know exactly when we will see that report; CMS just indicates that it will come out in 2023,” Wehri said. “We do know that the TEP provided input on a potential cross-setting health equity structural Composite Measure. And they did have the opportunity to look at additional health quality measure concepts, additional approaches to addressing health equity and data collection.”
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