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Special Focus Program Reform Needed!

Congress mandated a hospice Special Focus Program in 2020, with the intent of improving quality of care in hospice. A Technical Expert Panel (TEP) was convened by CMS to design the program. The hospice community has long called upon CMS to provide support and structure, through a Special Focus Program (SFP), to improve quality of care of poor-performing hospices for patients and families.

On November 1, CMS released its final rule to create and implement a hospice Special Focus Program beginning in 2024. Despite the claim that the hospice SFP will address program integrity problems, CMS has provided a program that utterly lacks integrity. It does not address any concerns by bipartisan members of Congress (including the original author of the legislation), its own members of the TEP, or the hospice community as a whole.

CMS’ current program will use an algorithm to identify the “lowest 10% performing hospice providers” and target them with severe enforcement, including high potential for deactivation. The algorithm to identify low performers would look at survey results, the Hospice Care Index (HCI) score, and Consumer Assessment of Healthcare Providers and Systems (CAHPS) scores. Reliance on these metrics is a glaringly flawed approach and will fail to actually identify the poorest-performing hospices.
CAHPS data is highly weighted in the algorithm—but less than half of hospices have CAHPS data. If a hospice lacks CAHPS data, they get an automatic average score. This approach is inequitable and inaccurate.
The algorithm relies upon outdated survey data. 1 in 3 hospices have not been surveyed in the last 3 years as required by law. CMS has no plan to address this backlog.
CMS will not give technical or educational support to hospices who are identified as low-performing and thus offer little hope to expect these hospices to improve and continue to serve their communities.

If this SFP is implemented, CMS will severely punish hospices, and patients who need them, for its own lack of accurate and adequate data and without any attempt
to improve care.

We ask that Congress, in an end of year package, require:
CMS reconvene its TEP and implement a new algorithm to properly identify poor-performing hospices
The SFP to send hospices a preview report and allow opportunity to contest performance score if based on bad data
CMS to provide technical assistance to correctly identified SFP hospices

The hospice community must raise the alarm NOW to get the proposed hospice Special Focus Program corrected before it does irreparable harm to providers and the vulnerable patients and families who rely on and deserve high-quality care. Contact your Members of Congress today!

Special Focus Program Reform Needed!

Congress mandated a hospice Special Focus Program in 2020, with the intent of improving quality of care in hospice. A Technical Expert Panel (TEP) was convened by CMS to design the program. The hospice community has long called upon CMS to provide support and structure, through a Special Focus Program (SFP), to improve quality of care of poor-performing hospices for patients and families.

On November 1, CMS released its final rule to create and implement a hospice Special Focus Program beginning in 2024. Despite the claim that the hospice SFP will address program integrity problems, CMS has provided a program that utterly lacks integrity. It does not address any concerns by bipartisan members of Congress (including the original author of the legislation), its own members of the TEP, or the hospice community as a whole.

CMS’ current program will use an algorithm to identify the “lowest 10% performing hospice providers” and target them with severe enforcement, including high potential for deactivation. The algorithm to identify low performers would look at survey results, the Hospice Care Index (HCI) score, and Consumer Assessment of Healthcare Providers and Systems (CAHPS) scores. Reliance on these metrics is a glaringly flawed approach and will fail to actually identify the poorest-performing hospices.
CAHPS data is highly weighted in the algorithm—but less than half of hospices have CAHPS data. If a hospice lacks CAHPS data, they get an automatic average score. This approach is inequitable and inaccurate.
The algorithm relies upon outdated survey data. 1 in 3 hospices have not been surveyed in the last 3 years as required by law. CMS has no plan to address this backlog.
CMS will not give technical or educational support to hospices who are identified as low-performing and thus offer little hope to expect these hospices to improve and continue to serve their communities.

If this SFP is implemented, CMS will severely punish hospices, and patients who need them, for its own lack of accurate and adequate data and without any attempt
to improve care.

We ask that Congress, in an end of year package, require:
CMS reconvene its TEP and implement a new algorithm to properly identify poor-performing hospices
The SFP to send hospices a preview report and allow opportunity to contest performance score if based on bad data
CMS to provide technical assistance to correctly identified SFP hospices

The hospice community must raise the alarm NOW to get the proposed hospice Special Focus Program corrected before it does irreparable harm to providers and the vulnerable patients and families who rely on and deserve high-quality care. Contact your Members of Congress today!