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Webinar | Home Health, Hospice, Membership

NAHC and NHPCO FY 2024 Proposed Rule – Listening Session 2

May 9, 2023

NAHC and NHPCO FY 2024 Proposed Rule – Listening Session 2



In addition to routine annual payment changes, the FY2024 hospice proposed rule is heavily weighted with data and insights on hospice utilization and performance in areas including non-hospice spending, live discharges and CMS concern about reports of limited availability of some palliative therapies (e.g. dialysis, radiation, etc.) signaling CMS’ intensified interest in these areas. A proposal that would require physicians who order or certify Medicare hospice services be enrolled in the Internet-based Provider Enrollment, Chain, and Ownership System (PECOS) or have a valid opt-out in order for the hospice services to be covered further shows CMS’ concerns about hospice program integrity. Beyond these concerns, CMS focused on health equity and hospice quality.

NAHC and NHPCO are working together to develop comments to the two Requests for Information (RFIs) included in the rule

  • Hospice Utilization; Non-Hospice Spending; Ownership Transparency; and Hospice Election Decision-Making
  • Health Equity as well as
  • the proposal for physician PECOS enrollment/valid opt-out
  • future quality measures