CMS to Update Hospice CoPs

The U.S. Centers for Medicare & Medicaid Services (CMS) has begun the process of revising the hospice Conditions of Participation (CoPs) for the first time in 20 years.

The agency’s Center for Clinical Standards & Quality (CCSQ), Clinical Standards Group (CGS), announced the project in late September. On Thursday, LeadingAge, an advocacy group of nonprofit senior care providers, released a statement alerting members to the forthcoming changes.

“The Conditions of Participation (CoPs) for hospice providers have not undergone major revisions in nearly two decades,” Mollie Gurian, vice president of policy and government affairs with LeadingAge, told Hospice News in an email. “A review of them is probably overdue — and not just because of the current focus on fraud and abuse in the Medicare programs. For instance, over the past several years, even prior to the current administration’s push, LeadingAge has recommended numerous changes to strengthen program integrity through the CoPs and the survey and certification process.”

CMS will hold three listening sessions with stakeholders to discuss and gather feedback on the CoPs and what they may change. The first is scheduled for Oct. 6 for hospice administrators and management, and the second will take place on Oct. 7 for direct care workers. The third happens on Oct. 14 for patient caregivers and families.

During these sessions, CMS plans to address a lengthy list of questions, LeadingAge reported, including the following:

• Are there existing CoPs that no longer reflect how hospice care is delivered today? If so, which CoPs should CMS prioritize for modernization?
• What operational challenges do hospices experience when trying to establish contracts with hospitals, rehabilitative therapists, etc.?
• What workforce challenges have had the greatest impact on your ability to provide hospice services?
• What internal controls exist to prevent the enrollment of patients who do not meet hospice eligibility criteria?
• What barriers prevent hospices from providing all Medicare-covered hospice services to patients?  
• What policy changes would have the greatest impact on improving patient care while also reducing opportunities for fraud or inappropriate enrollment?  
• In your role, how often do you interact with the hospice medical director? Please describe your interactions and experiences with the medical director.

The agency also developed an additional set of questions for caregivers and families.

“Exploring potential changes that would strengthen program integrity and quality, as well as ensure that any changes protect and promote good hospice care, just makes sense,” Gurian said. “The CMS listening sessions will provide a foundation for that work and a valuable forum for our members and providers across the country to share real-world perspectives on the questions guiding this initiative.”