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June 27, 2007
Ms. Leslie Norwalk, Esq.
Acting Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Room 445-G, Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, D.C. 20201
ATTN.: CMS-1539-P
Re: Medicare Program; Hospice Wage Index for Fiscal Year 2008; Proposed Rule,
Federal Register, Volume 72, No. 83, Tuesday, May 1, 2007
Dear Ms. Norwalk:
On behalf of our approximately 200 member hospitals and health care systems,
the Illinois Hospital Association (IHA) is taking this opportunity to formally
comment on the proposed rule establishing the wage index values for hospice
services for fiscal year 2008. IHA presents the following comments for your
consideration:
Annual Update to the Hospice Wage Index:
The rule provides for a full market basket payment update for FY 2008;
rates are scheduled to be published at a later date. While the Illinois
Hospital Association supports CMS’ implementation of the full update amount,
it urges CMS to publish the rates for the four hospice levels of care
(whether proposed or final) as part of the Federal Register notice of the
changes to the wage index. The proposed rule indicates that the adjustments
to the specific payment rates were not incorporated into the proposed rule
"...Due to the need to ensure appropriate time for implementing changes..."
This vague explanation for the omission of these rates is puzzling,
especially in light of the fact that for all other levels of service (i.e.,
inpatient or outpatient acute, rehabilitation, skilled nursing, psychiatry
or home health), payment rules as published in the Federal Register always
list the base payment rates. The publishing of these rates in the same
Federal Register in which the wage index values are published will
facilitate easier reference for hospice providers and others.
Site of Service:
The rule provides that effective with services furnished on or after
January 1st, 2008, payment to the hospice will be based upon the wage index
value assigned to the area where the hospice services were provided, as
opposed to the area where the hospice corporate office is located. While
this recommendation is consistent with the Medicare payment rules for home
health services, CMS does acknowledge that current hospice billing
information does not provide site-of-service locations. It is not known at
this time what additional administrative burdens this requirement would
place on hospice providers, nor is the dollar impact of such a change known.
CMS states: "Therefore, we are unable to predict the savings or costs
associated with the changes associated with this proposed provision."
Therefore, while the Illinois Hospital Association supports, in theory, the
proposed site of service payment rule, it suggests that CMS suspend its
implementation of this rule until such time as accurate site of service data
can be obtained from providers and subsequently, a reasonable estimate of
the dollar impact of this change can be made.
Ms. Norwalk, thank you again for the opportunity to comment. The Illinois
Hospital Association also welcomes the opportunity to work with your agency in
the continued development and refinement of the Medicare payment system for all
providers.
Sincerely,
Thomas A. Jendro
Senior Director, Finance
Illinois Hospital Association
(630) 276-5516
tjendro@ihastaff.org
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