Proposed CMS Amendment for Community-Based Palliative Care in Medicare

The Centers for Medicare & Medicaid Services (CMS) have proposed an amendment to the 2027 Home Health Prospective Payment System, aiming to extend community-based palliative care under Medicare's existing home health benefits for patients with severe illnesses. This proposal, distinct from traditional hospice care, targets supporting patients earlier in their illness journeys. Stakeholders have a deadline of August 31 to submit their feedback on the proposal.

Fred Bentley of Bentley Health Strategies considers this a promising development, though it is likely to benefit only a select group of Medicare fee-for-service beneficiaries who are homebound and require skilled care. He acknowledged that while the proposal may improve patient access, it falls short of implementing a comprehensive overhaul for community-based palliative care.

Kyle Edmonds from the American Academy of Hospice and Palliative Medicine praised CMS for acknowledging the necessity of such care. However, he clarified that this proposal does not introduce a new benefit. Edmonds raised concerns about the practicality and adequacy of the flat 30-day payment structure within the existing home health framework.

Edmonds further highlighted the need for CMS to clearly define palliative care and consider collaborations with qualified healthcare providers that could impact billing practices. Challenges such as patient homebound status requirements and restrictions on new home health agency enrollments may hinder service expansion.

Jill Schwartz-Chevlin of Vynca appreciated the clarification distinguishing skilled palliative from hospice care, but noted limitations faced by non-homebound patients. She emphasized the need for a community-based model with a multidisciplinary approach, observing financial constraints imposed by current payment systems.

CMS plans to provide further guidance to define the role of palliative care within the Medicare home health benefit, focusing on promoting community-based services. As the agency moves towards finalizing the rule, questions remain concerning reimbursement levels and service scope under the Home Health Patient Driven-Groupings Model.

Stakeholders are encouraged to engage with CMS' Request for Information to ensure that industry insights help shape a feasible framework for palliative care services within Medicare. Schwartz-Chevlin underscores the importance of timely industry feedback to influence the potential benefit development for Medicare beneficiaries.