A blood transfusion request for information (RFI) is in the proposed hospice rule from the Centers for Medicare & Medicaid Services (CMS). The agency recently announced the pending publication of the fiscal year (FY) 2025 hospice payment rate proposed rule on April 4th. An unpublished version of the proposed rule is available in the Federal Register after being filed on March 28th.
The blood transfusion RFI hospice proposed rule titled, “FY 2025 Hospice Wage Index and Payment Rate, Hospice Conditions of Participation, and Hospice Quality Reporting Program Requirements” solicits comments regarding potential implementation of a separate payment mechanism to account for high intensity palliative care services, including blood transfusions. The blood transfusion RFI in the CMS proposed hospice rule explains that CMS is considering a major potential shift away from a closed hospice bundled payment to allow for patient access to services like blood transfusions.
The blood transfusion RFI in the CMS proposed hospice rule builds on last year’s rule which asked about palliative services that were unavailable to patients enrolled in hospice or that retention of these services dissuaded or delayed enrollment in hospice. ABC joined the blood community in responding in accordance with our advocacy agenda ask regarding expanding access to palliative blood transfusions for patients at the end-of-life desiring hospice services.
Specifically, CMS is seeking comments on the following questions in the blood transfusion RFI in the CMS proposed hospice rule:
- “[w]hat could eliminate the financial risk commenters previously noted when providing complex palliative treatments and higher intensity levels of hospice care?
- What specific financial risks or costs are of particular concern to hospices that would prevent the provision of higher-cost palliative treatments when appropriate for some beneficiaries? Are there individual cost barriers which may prevent a hospice from providing higher-cost palliative care services? For example, is there a cost barrier related to obtaining the appropriate equipment (for example, dialysis machine)? Or is there a cost barrier related to the treatment itself (for example, obtaining the necessary drugs or access to specialized staff)?
- Should there be any parameters around when palliative treatments should qualify for a different type of payment? For example, we are interested in understanding from hospices who do provide these types of palliative treatments whether the patient is generally in a higher level of care (CHC, GIP) when the decision is made to furnish a higher-cost palliative treatment? Should an additional payment only be applicable when the patient is in RHC?
- Under the hospice benefit, palliative care is defined as patient and family centered care that optimizes quality of life by anticipating, preventing, and treating suffering (§ 418.3). In addition to this definition of palliative care, should CMS consider defining palliative services, specifically regarding high-cost treatments? Note, CMS is not seeking a change to the definition of palliative care, but rather should CMS consider defining palliative services with regard to high-cost treatments?
- Should there be documentation that all other palliative measures have been exhausted prior to billing for a payment for a higher-cost treatment? If so, would that continue to be a barrier for hospices?
- Should there be separate payments for different types of higher-cost palliative treatments or one standard payment for any higher-cost treatment that would exceed the per diem rate?”
Comments on the blood transfusion RFI hospice proposed rule are due May 28th.