Hospices need to be aware of regulatory and reimbursement trends taking place across the care continuum.

Annual payment rules from the U.S. Centers for Medicare & Medicaid Services (CMS) often include regulatory updates that can trickle effects in other health care sectors, according to Katie Wehri, vice president for regulatory affairs, quality and compliance at the National Alliance for Care at Home. These updates can also signal where the agency is headed from an overall payment and oversight standpoint, Wehri said during the Hospice News Payment Summit.

“Don’t just focus on the hospice rule,” Wehri told Hospice News during the summit. “Looking outside of the hospice rule is important because there could be regulations, for instance, in the home health rule or the physician fee schedule rule, that impact hospices that we need to be aware of. [It’s] thinking about the vehicles that CMS could use to put forth some of the regulations that they would really like to see changed, especially as it relates to program integrity for hospices and overall for all providers. Always scan for those [changes].”

Understanding the different updates occurring across the care continuum has been particularly important for hospices seeking service diversification, said James Dismond, CEO of MiraSol Health. The South Carolina-based nonprofit provides hospice, palliative care and bereavement.

MiraSol Health recently expanded its community-based palliative care program and launched a behavioral health business. These service diversification efforts were in part designed to strengthen timely access and involved a deeper examination of payment avenues outside of the Medicare Hospice Benefit, Dismond indicated.

“Diversification of our business is super important for home care in general,” Dismond told Hospice News during the summit. “This was all because we needed to survive, and we needed to get referrals in a timely manner, so that we weren’t accruing a huge cost for those late referrals. That has helped us tremendously, because we’ve had almost a 300% growth in our business over the past 18 months. So, looking at ways to stay within your mission of providing home care, but you’re adding services that are billable in nature.”

Hospices have kept a watchful eye on changes in value-based care reimbursement that could impact both service diversification potential and sustainability, Dismond said.

Among the significant updates was the end of the hospice component of the value-based insurance design (VBID) model, which expired on Dec. 31, 2024. Commonly known as the “Medicare Advantage hospice carve-in,” the program was designed to test hospice care coverage through Medicare Advantage, as well as some coverage of palliative care and transitional care. The hospice component, which launched in 2021, is part of the larger VBID demonstration, which covers a wider breadth of the health care continuum and is slated to continue until 2030.

Understanding the potential impacts of payment demonstrations like the Medicare Advantage carve-in can be important for hospices as they determine strategies for long-term sustainability, Dismond said.

“It is super important to pay attention to other regulatory components and also legislation that affects care in the home,” Dismond told Hospice News during the summit. “We want to preserve the long-standing safeguard that ensures hospice services to continually operate, specifically around Medicare Advantage beneficiaries. We want them to be able to access hospice through traditional Medicare. Hospice is a proven benefit, it’s proven to save the nation money. So, having Medicare Advantage carve that in or out, we want it to stay within Medicare traditional benefits.”

A significant roadblock for hospice VBID was that eligibility requirements for palliative, transitional concurrent and hospice supplement benefits differed from plan to plan, according to an analysis report from RAND Health Care. Hospice participants also reported challenges related to claims processes including delayed or denied claims that were resource intensive and time consuming.

The future of Medicare Advantage reimbursement is top of mind for many hospices, particularly smaller organizations struggling to compete in today’s economic climate, said Christie Rivelli, co-founder, nurse practitioner and executive director of Oregon-based Solterra Hospice. While hospices are seeking more ways to fuel their services, seeking avenues outside of traditional Medicare could result in inconsistencies in terms of quality and scope of services, she indicated.

“Look at how far we’ve come with advocacy, but also look at how far we have to go,” Rivelli said. “Really looking at keeping Medicare managing the hospice benefit, rather than it going to secondary payers. Rather than having Medicare Advantage plans meaning the hospice benefit, which would also add a layer of complication and just a lack of uniformity.”