The Hospice Carve-In Is Coming: Build Your MA Engagement Plan NOW!

The Centers for Medicare and Medicaid Services (CMS) recently announced in a press release its upcoming 2019 test with select Medicare Advantage plans for what has been called a hospice carve-in whereby Medicare Advantage plans may offer hospice as a benefit in 2021. A hospice carve-in may create a new environment for how hospice providers access referrals and how they are reimbursed for their services.

Medicare Advantage plan membership continues to grow in this country. In 2018, there were 20.8 million Medicare beneficiaries enrolled in a Medicare Advantage Plan which represents 34% of all Medicare enrollees up 16% from 2017 with projections for continued growth. With a hospice carve-in, there is potential concern among hospice providers that Medicare Advantage members that elect hospice may be restricted or directed to use a select list of hospice organizations. Currently, a Medicare Advantage member who elects to use hospice goes back onto the Fee for Service Medicare benefit, and may choose any hospice serving their area. With a Medicare Advantage carve-in, hospice organizations may need to be “in-network” with that Medicare Advantage plan for plan members to choose their hospice services. How Medicare Advantage plans may select their in- network providers is new territory for both the plans and hospice organizations.

 An unfortunate precedent has been set with home health services. Home health providers have complained that many MA plans do not pay providers a rate of reimbursement commensurate with that of the Medicare fee-for-service. There may also be requirements for prior authorization and late payments. Based on what we know, it’s fair to say that Medicare Advantage plans may underestimate the complexities of supporting families in the loved one’s last year of life.  

 What immediate actions should hospice organizations take?  

 1.     Identify and engage local Medicare Advantage Plan stakeholders. This should include conducting a needs assessment for the plans’ MA membership to identify their greatest challenges and their interest in hospice collaborations.

 2.     Develop a hospice performance scorecard. This should demonstrate quality measures and cost curving capabilities in comparison to other hospice organizations in your market. Hospice may be competing for “in-network” status which means that Medicare Advantage plans will look to evaluate one hospice from another.

 3.     Pursue value-based partnerships with your local health systems and other large existing referral sources.  This may include serving a specific high-cost Medicare Advantage population that the health system would directly gain a cost savings and quality boost from a closer collaboration.

 Most hospice organizations lack the time and expertise in executing these initiatives. Consider reaching out to industry expertise in this area to nail down the goals, set objectives and benchmarks, and work with your team to execute the plan. It’s important get on track with these changes - and what they mean for your organization - fast.

References:

“A Dozen Facts About Medicare Advantage,” Henry J Kaiser Foundation,  https://www.kff.org/medicare/issue-brief/a-dozen-facts-about-medicare-advantage/

“CMS to Test Hospice Carve-In Under Medicare Advantage,” Home Healthcare News, https://homehealthcarenews.com/2019/01/cms-to-test-hospice-carve-in-under-medicare-advantage/

 Medicare Advantage/Part D and Enrollment Data, “Research Statistics Data and Systems: Statistics, Trends and Reports,” https://www.cms.gov/Research-Statistics-Data-and-Systems/Statistics-Trends-and-Reports/MCRAdvPartDEnrolData/index.html

 “Medicare Advantage Value-Based Insurance Design Model,” https://innovation.cms.gov/initiatives/vbid.