7

Hospice Care in the United States

According to estimates of the National Hospice and Palliative Care Organization,

there were approximately 5,800 hospice programs in the United States in 2013. In

that year, 42.9% of all deaths in the United States occurred under hospice care.

7,8

Hospices provided care for patients with various terminal illnesses (e.g., cancer

[36.5% of all admissions], heart disease [13.4%], dementia [15.2%], and lung

disease [9.9%]).

7 During the Medicare demonstration project (1980–1982), 93% of

home hospice patients had cancer of various types.

9

Adults younger than 34 years of age and pediatric patients account for less than 1%

of the hospice population. Although pediatric hospice programs are growing, and

more pediatric patients receive hospice services, the percentage of patients in this

population has not increased from 2006 to 2013.

10 Regulatory, financial, cultural, and

educational barriers play a role in diminished access to hospice care for pediatric

patients.

10,11 States are required to offer hospice care (under Medicaid and other state

programs as part of the Affordable Care Act) to pediatric patients with expanded

benefits to improve coordination of care.

12

About 84% of hospice patients were 65 years of age or older, and 41.2% were 85

years or older and in 2013, 87.2% of hospice patients received this care as a benefit

provided by Medicare. Almost all (92.7%) hospice programs are certified by the

Centers for Medicare and Medicaid Services to provide care to beneficiaries under

the Medicare Hospice Benefit.

7

The Medicare Hospice Benefit

The Medicare Hospice Benefit is funded from Part A (the hospital portion) of

Medicare.

13 Patients are eligible for this benefit if, in the opinion of two physicians

(i.e., patient’s primary-care physician and hospice medical director), the natural

course of their disease will result in death within 6 months. The hospice medical

director determines the terminal diagnosis and any other conditions related to the

terminal prognosis. Eligibility for hospice can continue beyond the initial

certification if the hospice medical director recertifies eligibility at defined intervals,

called certification periods. Other insurance payers generally follow this criterion. In

electing this benefit, patients agree to relinquish their regular Medicare benefits as

they relate to the terminal illness and related conditions and accept the palliative

rather than curative approach that will be provided by hospice. This benefit links all

care related to these diagnoses to the selected Medicare-certified hospice program,

which coordinates and provides all care. The regulatory framework for the provision

of hospice care under Medicare is defined in 42 CFR Part 418, Medicare and

Medicaid Programs: Hospice Conditions of Participation.

13

Hospice care is provided (and reimbursed) under Medicare at four levels, all of

which can be modified at any time based on a patient’s condition or caregiving

needs:

Routine home care (day-to-day care in the home)

Continuous home care (when more skilled care in the home is required owing to

symptom management or a caregiving crisis)

General inpatient care (reimbursement for an inpatient stay in a hospital or skilled

nursing facility related to symptoms that cannot be managed in the home)

Inpatient respite care (up to 5 days in a skilled nursing facility) to give the caregiver

a break or respite

Most care, consisting of pain and symptom management and assistance with

activities of daily living, as well as psychosocial support, is provided to hospice

patients at the routine level of care.

Patients may freely visit their primary-care provider (i.e., physician or nurse

practitioner) for any reason, including reasons unrelated to their terminal illness. The

primary-care provider will be paid directly by Medicare. Patients may choose to use

their regular Medicare benefits for other unrelated illnesses; visits to providers for

care or treatments unrelated to the primary hospice diagnosis are not limited or

restricted. Patients may revoke their election of the Medicare Hospice Benefit at any

time (e.g., end hospice care to pursue curative treatment or seek treatment outside the

hospice plan of care). Patients may, at a later date, choose to return to hospice care

or change to a different hospice program, without restrictions or loss of benefits.

13

It is common for patients to be referred to hospice when death is imminent. Median

lengths of stay have declined, from 37.1 days during the Medicare demonstration

project (1980–1982) to 26 days in 2005 and to 18.5 days in 2013.

7,9,14 Approximately

34.5% of patients admitted to a hospice program in 2013 died or were discharged

within 7 days.

7

Hospice programs have historically received a fixed daily payment to provide all

care related to the terminal diagnosis (e.g., medications, supplies, durable medical

equipment, procedures, home health aides, provider visits, spiritual care,

bereavement services). The reimbursement rates for the four levels of hospice care

under the Medicare Hospice Benefit are established each summer for the following

fiscal year, effective October 1.

15 A baseline reimbursement rate is set, along with an

adjustment for wage differentials (the wage index) based on the local cost of

living.

15,16 As an example, Table 6-1 shows reimbursement rates for the provision of

routine home care in San Francisco, CA, and Jefferson City, MO, for fiscal year

2016 up to December 31, 2015. Historically, hospice reimbursement rates have been

low and have not kept pace with rising costs. The total unadjusted hospice daily

payment rate increased from $146.63 per day to $161.89 per day from 2011 to 2016

(approximately 2.1% per year).

15,17

Table 6-1

Example of Hospice Daily Payment Rates for Routine Level of Care, 2016

Fiscal Year (October 1, 2015–September 30, 2016)

14,15

A

Unadjusted

Payment

Rate (B 1 C)

B

Nonlabor

Portion

C

Labor

Portion

D

Wage Index

E

Adjusted

Labor

Portion (C 3

D)

F

Total Daily

Payment (B

1 E)

San Francisco,

CA

$161.89 $50.66 $111.23 1.7260 $191.98 $242.64

Jefferson City,

MO

$161.89 $50.66 $111.23 0.9366 $104.18 $154.84

p. 84

p. 85

Programs generally have high costs at the start of care because of personnel costs

involved in the admission, assessment, and development of the initial plan of care,

and obtaining medications, medical equipment, and medical supplies. High costs are

also encountered nearer to the end of life, when new problems can appear and

symptoms often intensify. The Centers for Medicare and Medicaid Services are

implementing hospice payment reform beginning January 1, 2016, consisting of

higher payments at the start of care (for days 1–60) and near the end of life via a

service intensity add-on (SIA) to account for greater care needs during these

periods.

15

It is anticipated that future reforms may include differing payments based

on where the beneficiary resides (home versus a facility), including hospice care in

Medicare Advantage plan coverage, or on the type of care provided, on quality

outcomes, and on expanding the definition of what is related to the terminal

prognosis.

18

Drug costs continue to outpace increases in hospice reimbursement.

19

In 2014,

overall drug spending in the United States increased 13.1% due primarily to

increased prices for brand, niche ,and specialty drugs; increases in prices for

compounded medications; and shortages resulting from industry consolidation. Prices

for drugs for pain and inflammation increased by 15.7% in 2014. This is attributed by

Express Scripts in part to new tamper-resistant formulations where there is no

generic alternative.

19

In reviewing hospice beneficiary use of Medicare Part D, CMS has reminded

Medicare Part D Plans, pharmacies, and hospices that hospices are required to pay

for virtually all care (including all related medications) for hospice patients (via Part

A). An initiative to block Part D access to hospice patients was subsequently

reversed by CMS with the clear expectation that hospices provide analgesics,

antiemetics, laxatives, and anxiolytics and to coordinate drug coverage with the Part

D plans.

20–22 Hospices are allowed to establish formularies, but if the hospice does

not provide a related medication for any reason, the beneficiary may not use their

Part D plan to obtain it. The result has been hospices paying for many more

medications than in the past (i.e., covering medications used to treat rather than just

palliate related conditions).

These variables (i.e., referrals to hospice later in the course of terminal illness,

higher costs at the start of care, shortened lengths of stay, higher drug costs, providing

more medications) have placed intense pressure on hospice programs to manage

expenses. Because it is difficult to influence the time when patients are referred to

hospice, the duration of time in hospice care, or the inherently higher costs when

patients are first enrolled into hospice, the management of drug costs has taken a high

priority in providing cost-effective hospice care.

Improving Patient Care and Managing Drug Costs

In 2008, the Hospice Conditions of Participation were updated to be more patient

centered and outcome oriented.

13 Coverage of medications is mandated as described

in 24 CFR §418.106 Drugs and biologicals, medical supplies, and durable medical

equipment: “. . .drugs and biologicals related to the palliation and management of the

terminal illness and related conditions, as identified in the hospice plan of care, must

be provided by the hospice while the patient is under hospice care.”

It also addresses medication management and the review of the medication profile

specifying that “[t]he hospice must ensure that the interdisciplinary group (IDG)

confers with an individual with education and training in drug management as defined

in hospice policies and procedures and State law . . . to ensure that drugs and

biologicals meet each patient’s needs.”

The regulations state that the comprehensive assessment must “take into

consideration” the drug profile (24 CFR §418.54). This is defined as “[a] review of

all of the patient’s prescription and over-the-counter drugs, herbal remedies and

other alternative treatments that could affect drug therapy” and is to include the

following:

Effectiveness of drug therapy

Drug side effects

Actual or potential drug interactions

Duplicate drug therapy

Drug therapy currently associated with laboratory monitoring

Although the regulations do not specify who is to perform the medication

assessment, pharmacists are uniquely qualified to fill this role.

Well-trained pharmacists can improve patient care and positively affect the fiscal

margins of hospice programs by discouraging inappropriate use of medications,

establishing evidence-based formularies, promulgating prior authorization policies

for specific targeted drugs, establishing policies for adhering to the use of generic

drugs, and managing the quantities of medications to be dispensed. In addition to

managing drug expenditures, pharmacists provide drug information both to patients

and providers and work integrally with other members of the hospice health care

team to improve the safe and effective use of medications.

23–37

Referral to Hospice

ELIGIBILITY

CASE 6-1

QUESTION 1: M.P. is an 89-year-old woman referred to hospice for end-stage Alzheimer dementia. She

lives in a residential care home for the elderly with a hired caregiver. Her husband has been unable to care for

her at home for some time because she requires full assistance with all activities of daily living. She was

recently hospitalized with aspiration pneumonia and a urinary tract infection (UTI) and completed a course of

intravenous (IV) vancomycin and piperacillin/tazobactam. Her past medical history includes osteoporosis,

coronary artery disease, chronic obstructive pulmonary disease (COPD), hypercholesterolemia, and

hypothyroidism. She is not oriented to person, place, or date. Her speech is unintelligible or nonsensical. She

cannot feed herself, but will eat the thick pureed food that is fed to her. She is bed-bound and incontinent of

urine and stool. She is restless and irritable at times, especially at night. Her Palliative Performance Scale (PPS)

is 30%. Weight is 112 pounds, decreased from 135 pounds a year ago, and a recent serum albumin is 2.2 g/dL.

What criteria does M.P. meet for eligibility for hospice services under the Medicare Hospice Benefit?

Patients with chronic diseases (e.g., Alzheimer disease, Parkinson disease, stroke,

heart failure, lung disease) can be sufficiently ill and debilitated to need custodial

care, but might not be sufficiently ill to meet the definition of a terminal illness. This

differentiation between terminally ill versus chronically ill requiring custodial care

is important because to qualify for hospice services under the Medicare Hospice

Benefit, patients must be at a stage where death is expected within the next 6 months.

For cancer diagnoses, the presence

p. 85

p. 86

of widespread metastatic disease may make this prognosis more easily evident.

However, for other chronic diseases, this is not as clear.

The Medicare fiscal intermediaries have issued criteria to assist in the

determination of eligibility for hospice care, as well as criteria to meet a 6-month

terminal prognosis for a number of diseases. These criteria, or local coverage

determinations (LCDs), provide guidelines for meeting an overall decline in clinical

status, for meeting non–disease-specific data to establish a baseline, for establishing

the effect of comorbidities (e.g., renal failure, liver disease), and for the submission

of documentation for having met criteria. Criteria have been established for patients

with cancer and non-cancer diagnoses, and these criteria are used in the

determination of eligibility for service and reimbursement.

38 Criteria for the non-

cancer diagnoses have been developed for amyotrophic lateral sclerosis, dementia as

a result of Alzheimer disease and related disorders, heart disease, human

immunodeficiency virus disease, liver disease, pulmonary disease, renal disease,

stroke, and coma. Patients with cancer are eligible if they present with metastatic

disease or progression from an earlier stage to metastatic disease with either a

continued decline in spite of therapy or if they decline further disease directed

therapy.

The determination of whether M.P. meets eligibility requirements for Medicare

Hospice Benefits must be based on the established LCDs for dementia as a result of

Alzheimer disease. These criteria include the following:

Stage 7 or beyond, according to the Functional Assessment Staging Scale

Stage 7A: Can speak six or fewer intelligible words in a day or during an

interview

Stage 7B: Speech ability limited to the use of a single intelligible word in a day

or during an interview

Stage 7C: Cannot ambulate without assistance

Stage 7D: Cannot sit up without assistance

Stage 7E: Loss of ability to smile

Stage 7F: Loss of ability to hold head up independently

Unable to ambulate without assistance

Unable to dress without assistance

Unable to bathe without assistance

Urinary and fecal incontinence, intermittent or constant

No consistently meaningful verbal communication; stereotypical phrases only or the

ability to speak is limited to six or fewer intelligible words

One of the following within the past 12 months: aspiration pneumonia,

pyelonephritis, septicemia, decubitus ulcers (multiple, stages 3 and 4), fever

(recurrent after antibiotic treatment)

Inability to maintain sufficient fluid and caloric intake with 10% weight loss during

the previous 6 months or serum albumin less than 2.5 g/dL

The Palliative Performance Score (PPS) (Table 6-2) gradates the extent of

disability and can be used to assist in the determination of hospice eligibility.

39 M.P.

meets the previous criteria and is eligible for hospice because of her Alzheimer

disease. She clearly is debilitated. She is unable to speak intelligently, cannot feed

herself, is not oriented to time or place, is incontinent of urine and stool, has lost

about 20% of her weight during the past year, has a serum albumin of 2.2 g/dL, and

has a PPS rating of 30% (i.e., totally bed-bound, unable to do any activity, confused).

In addition, she has a number of comorbidities, experienced a recent episode of

aspiration pneumonia, and finished a course of antibiotic therapy.

MEDICATION MANAGEMENT

CASE 6-1, QUESTION 2: M.P. has no known allergies. Her current medications are memantine 10 mg

twice daily, aspirin 81 mg once daily, alendronate 70 mg weekly, esomeprazole 20 mg daily, lovastatin 20 mg

with dinner, megestrol 40 mg/mL 5 mL (200 mg) twice daily, levothyroxine 0.1 mg daily, multivitamin daily,

beclomethasone metered-dose inhaler one puff daily, albuterol 2.5 mg/ipratropium 0.5 mg via nebulizer every 4

hours as needed for wheezing or shortness of breath, acetaminophen 325 to 650 mg every 6 hours as needed

for mild pain or fever, olanzapine 5 mg at bedtime as needed for restlessness and aggressive behavior, milk of

magnesia 30 mL daily for constipation, and a bisacodyl suppository 10 mg every 3 days as needed if no bowel

movement. The hospice medical director has determined that the aspiration pneumonia, UTI, and COPD are

related to M.P.’s terminal prognosis. What is your assessment of M.P.’s medication regimen? Which

medications are the hospice required to provide, and which might be discontinued?

Hospices are required to provide (pay for) all medications related to the terminal

diagnosis and related conditions within the hospice plan of care (POC). The POC is

the individualized plan of treatment developed for each patient formulated at the start

of care and updated regularly by the IDG. The Conditions of Participation mandate

that the IDG be composed of a physician, registered nurse, social worker, and a

pastoral or other counselor.

13 A registered nurse coordinates the implementation of

the POC. Some hospice program IDGs have incorporated a pharmacist into the group

to review medication issues.

The large array of medications being taken by M.P. is similar to the medication

lists of many hospice patients. These patients are often elderly and have a long

history of several chronic medical conditions for which they have been taking

multiple medications. In most cases, the medication lists of patients who are admitted

into a hospice program have seldom been reviewed, updated, or modified in light of

the present medical situation. Admission to a hospice program represents a change in

the level of care and is a most appropriate time for a review and reconciliation of all

medications to ascertain the necessity of each, with the goal of optimizing efficacy

and minimizing the potential for adverse effects, medication errors, and inappropriate

costs.

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