NHPCO NewsLine Winter 2015 - (Page 26)

Short Takes NHPCO Leadership through Comment Letters NHPCO, as the leading voice recognized by regulators, administrators, and legislators strongly believes that our organization has a responsibility to submit official comment letters on proposed regulatory rules when they are released by the federal government. Comment letters, which become an important part of a project's public record, are an important source of information regarding constituents' views on and experiences related to proposed regulatory issues. Comment letters involve not only extensive staff time to research, collect information, and compose, but NHPCO's Health Policy Team collaborates with many professionals in the field as well as counsel and industry experts to craft comments that are constructive and clearly delineate the hospice and palliative care community's point of view. In 2015 alone, NHPCO's Health Policy Team submitted seven comment letters on a number of issues that are significant to our provider community. Few other national organizations contributed the same amount of feedback and suggestions to the government agencies. Here is a list of NHPCO's comment letters submitted in 2015: 1. FY2016 Hospice Wage Index (Submitted June 29, 2015) a. Two tiered payment system b. SIA payments c. All diagnoses on the claim form 2. Medicaid Managed Care (Submitted July 27, 2015) a. Statutory requirements for hospice in Medicaid b. Challenges from providers c. Request that CMS address hospice inclusion in Medicaid managed care as well as room and board payments when a nursing home resident elects hospice. 3. Physician Fee Schedule (Submitted September 8, 2015) a. Advance care planning codes b. Case management c. Support for separate code for collaborative care d. Physicians employed by rural health clinics and federally qualified health centers 4. Comprehensive Care for Joint Replacement Bundled Payment (Submitted September 8, 2015) a. Hospice included in bundle for 90 days post-surgery b. Definition of relatedness to the bundled payment, could be used as a model definition for other bundled payments 26 NHPCO NewsLine | Winter 2015 5. CDC Draft Guidelines on Prescribing Opioids for Chronic Pain (Submitted September 18, 2015) a. Commented on lack of transparency in the development process b. Commented on the addition of language if the patient is not competent for discussions about prescribing. 6. ICD-10 (Submitted October 7, 2015) a. Request for leniency for Part A providers, as is provided for Part B providers through the AMA-CMS joint announcement 7. Nursing Home Reform (October 14, 2015) a. Hospice specific issues - no extra charges for hospice services and information provided when patient is transferring b. Psychotropic medications and why they should be allowed for hospice and palliative care patients c. Role of the nursing home pharmacist and conflict with hospice Conditions of Participation regarding drugs and pharmacy review http://www.nhpco.org/sites/default/files/public/regulatory/NHPCO_Comment_FY2016HospiceWageIndex_Proposed.pdf http://www.nhpco.org/sites/default/files/public/regulatory/NHPCO-CommentLetter-CDC_Guidelines_Opioids-ChronicPain.pdf http://www.nhpco.org/sites/default/files/public/regulatory/NHPCO-CommentLetter-CDC_Guidelines_Opioids-ChronicPain.pdf http://www.nhpco.org/sites/default/files/public/regulatory/NHPCO_Comments_on_Medicaid_Managed_Care_Proposed_Rule.pdf http://www.nhpco.org/sites/default/files/public/regulatory/NHPCO_Comments_ICD-10_Letter-to-CMS-Onbudsman.pdf http://www.nhpco.org/sites/default/files/public/regulatory/Comment-Letter_Physician-Fee-Schedule.pdf http://www.nhpco.org/sites/default/files/public/regulatory/CommentLetter-NH-Reform.pdf http://www.nhpco.org/sites/default/files/public/regulatory/Comment-Letter_Bundled-Payment_LEJR.pdf http://www.nhpco.org/sites/default/files/public/regulatory/Comment-Letter_Bundled-Payment_LEJR.pdf

Table of Contents for the Digital Edition of NHPCO NewsLine Winter 2015

Issue Table of Contents
Management and Leadership Conference 2016 (display ad)
A Message From Don
Hospice Care in America: A Look at the Past Six Years
Hospice State Profiles (display ad)
ACHC Accreditation in your Field (display ad)
Simione Healthy Business Solutions (display ad)
Hospice Medical Director Certification
NHPCO Marketplace (display ad)
Helping You with Your Professional Development
Consolo Software for Hospice (display ad)
NHPCO 2016 Webinars (display ad)
We Honor Veterans 5th Anniversary
NHPCO Leadership through Comment Letters
Learning Collaborative to Relieve Caregiver Fatigue
ICU Toolkit form AHA
Volunteers Honored at CTC
Notes from NHPCO
2015 Creative Arts Contest
Member News
Life & Death Matters CE for Nursing Assistants (display ad)
Thanks to CTC 2015 Supporters
News From National Hospice Foundation
More from Moments of Life
Moments of Life T-shirt (display ad)
News From Global Partners in Care
Pay It Forward, GPIC (display ad)
NHPCO Career Center (display ad)
Links to Helpful Resources

NHPCO NewsLine Winter 2015