On February 16th, LeadingAge submitted a response to the Center for Medicare and Medicaid Innovation’s (CMMI) Request for Information (RFI) for the Value-Based Insurance Design Model (VBID). LeadingAge strongly advised CMMI to exert extreme caution regarding closed networks for hospice providers and strongly opposed any change to current prior authorization restrictions for the VBID Hospice Benefit Component.
LeadingAge also rejected the premise of two CMMI questions regarding “urgent care” and instead argued that all hospice services are medically necessary and immediately required. All hospice services should be protected regardless of whether a provider is in-network or out-of-network and any access safeguards implemented in the VBID program should have the sole purpose of protecting beneficiaries from delays in care which could reduce the days spent in hospice. LeadingAge strongly recommended CMS require plans to allow any willing hospice provider to participate if the provider meets the threshold for quality reporting or has been identified as having numbers too low to report.
In the current comprehensive network development strategy, CMS states it will review VBID Hospice Benefit Component applications to assess an MAO’s process to ensure their hospice provider networks have adequate capacity and provide three examples of adequacy including staffing. LeadingAge commented that allowing MAOs to define staffing expectations for contracted hospices would be irresponsible and potentially lead to access issues in the long term. Read the full RFI response here.
