While recent actions by the U.S. Centers for Medicare & Medicaid Services (CMS) could incrementally move the needle on palliative care access, they could also come with many limitations.
CMS in its proposed 2027 home health rule clarified that home health providers can use certain billing codes to provide community-based palliative care to eligible patients. The agency emphasized that this palliative care would be distinct from hospice
Stakeholders in the hospice community were quick to applaud the proposal
“We are pleased to see CMS recognize the value of palliative care and the important role it plays in improving quality of life for people living with serious illness both before hospice election and during it,” National Partnership for Healthcare and Hospice Innovation Founder and CEO Tom Koutsoumpas told Hospice News in an email. “NPHI has long advocated for greater access to, and sustainable payment for, palliative care services much earlier and throughout the course of serious illness, and we welcome CMS’s openness to advancing this work as an important step toward ensuring access for patients and families.”
The clarification in the proposed rule does not represent new policy or practices by CMS. The agency indicated that it would release further sub-regulatory guidance later this year on how home health agencies can provide palliative care
However, what CMS has done falls short of a community-based palliative care benefit. For one, patients must meet the eligibility requirements for home health. This means that, among other requirements, patients must be homebound to receive this care director of hospice and home health operations and policy for LeadingAge. This excludes many patients who may benefit from palliative care.
This also means that hospices with community-based palliative care programs cannot bill using those codes unless they have a Medicare-certified home health service
The palliative care model that exists within home health is also somewhat less robust than the services provided by hospices, Barnett indicated
“We do believe that home health is a good place for palliative care patients. I think one of the things that we’re struggling with is that, if we push palliative care into home health, the benefit really doesn’t support the same intensity of care as the hospice program,” Barnett told Hospice News. “It’s a really tight payment, and that’s why you see so few new home health agencies. It’s a really tough industry to be in right now, especially with the last four years of [payment] cuts.”
Existing quality measures for home health also do not incentivize the provision of palliative care. CMS evaluates home health largely on improvement measures that show a patient’s progression towards a recovery. They are not built for maintenance or comfort care, Katie Wehri, vice president for regulatory affairs, quality and compliance at the National Alliance for Care at Home.
“[Quality measurement] is an area where there needs to be some more work. The payment structure needs to be revised, but the quality structure does as well,” Wehri told Hospice News. “Those quality measures aren’t really aligned to the typical patient who’s going to be receiving palliative care services, or even the typical patient who is more of a maintenance patient rather than a patient who’s there for skilled rehab services.”
Wehri posits that the home health payment model does not cover the full range of interdisciplinary care that a hospice might provide, including chaplain service and more frequent social worker visits. She also said that the payment model needs to be updated to reflect the more acute level of care that palliative patients often need.
Also, the home health benefit does not require collaboration with a medical or advanced practice provider CEO of the Center to Advance Palliative Care (CAPC) and Allison Silvers, chief healthcare transformation officer at CAPC
“The home health team should have a formal collaboration with a qualified palliative care medical or advanced practice professional,” Bowman and Silvers told Hospice News in a joint email. “This is aligned with palliative care quality guidelines and CMS should clarify that the medical provider can bill Part B while the home health is billing Part A.”
All in all, stakeholders recognize this move by CMS as a positive step. But many also feel that further reforms or additional access points are necessary to truly meet the needs of patients who could benefit from palliative care
“I definitely think that acknowledging that palliative care services are part of home health is a step in the right direction,” Wehri said. “It is not where we need to be fully. We’ve got to take some steps to look at serious illness throughout the continuum of care, not just for those homebound patients.”
Companies featured in this article:
LeadingAge, National Alliance for Care at Home, National Partnership for Healthcare and Hospice Innovation
