Unpacking the FY 2025 Hospice Payment Final Rule

Intro
Welcome to the MHA Corner podcast, where we discuss news and developments in the post-acute space. Today we sit down with MHA chairman and co-founder Tom Maxwell alongside Jay Duty, COO at MHA. The pair discuss all things hospice in light of the FY 25 final rule, while unpacking reporting systems, rate updates, best practices and more.

Tom:
Hi, I'm Tom Maxwell. Good morning. Thank you for attending the podcast. Quick introduction to myself. I'm Tom Maxwell. I'm the Chairman and Co-founder of Maxwell Healthcare Associates. I'm also the founder of Muse Healthcare and the Non-executive Chairman of the board for Medalogix Products, as well as on the board of many other companies in the home care and hospice space Thank you for attending today.

Jay:
Thanks for joining us today. I'm Jay Duty. I'm the Chief Operating Officer of Maxwell Healthcare Associates. Excited to talk about the final rule today. We have a team of industry veteran experts that are ready to help hospice agencies really navigate this new rule. So excited to get into some of the details here.

So, Tom, can you give us a summary of some of the key takeaways of the final rule for hospice for the fiscal year of 2025 and what are some of the implications of how it's going to affect agencies?

Tom:
Yeah, for sure. Thanks, Jay. So, Medicare CMS, released the final rule a few weeks ago. They call it the 2025 hospice payment rule update. Good news is we got a 2.9% increase in payment. In the proposed rule, they put out a 2.6. So, they actually increased that a little bit.

And that's accounting for an estimated $790 million rise from 2024. So we get a raise in hospice. They updated the base rate, 3.9% inpatient hospice market basket increase and then offset by a 5% percentage point productivity adjustment. Another piece of it around hospice not submitting quality data. They're going to do a 1.1% decrease.

No reason that anybody should not submit their data. And we'll talk about that here a little bit, just to dive a little bit more into the rule. They also increased the hospice cap amount from 2025 to $34,465.34. We'll talk about the cap increase here in just a few minutes.

But I think that's a super interesting one as well. They also updated the quality reporting program. So, two new measures for the hospice quality reporting program called HQRP, and those are going to start in 2028, but they're going to start collecting data on them in 2025. So, it's going to be really important that you start answering these questions correctly because it's where you're going to get measured at and mostly their timely follow up on pain and non-pain symptoms.

So, if a patient's having pain, how often do you follow them up? They're going to also implement the HOPE patient level data collection tool. We'll get into that in lots of detail here in a few minutes, but just as a summary as well, included the specialty focused program. So, monitoring and improving the performance hospices.

These specialty focused programs essentially are areas where they see underperforming hospices, where they're going to come in and do audits and try to correct low performing hospices, especially around caregiver metrics and the amount of time and effort we're spending on patients. And they put a few technical updates into the rule as well.

So pretty simple rule, with the exception of the HOPE questions and processes that are coming in, and then the wage indexes and updates. So we'll jump deep into that. While we're talking about the cap, let's kind of jump into what, hopefully everybody knows what cap is, but cap is the allotted amount of money that you can spend per patient.

So, in hospice, you get a max cap. In 2021, that was $30,581.25. Last year it was $33,494.01, and now it's up to $34,465. So essentially what the cap does is that's the max dollar value that you can spend on a patient. So what they're trying to control in cap is the length of stay.

If all your patients are greater than x number of days in length of stay, you're going to have a challenge. That's how Medicare regulates the length of stay. If you take a dollar 200 per day per diem rate that we get for hospice, that's on average, some hospices dollar 265, some hospitals get dollar 220.

And so if you average it to 200, that equals 172 days, almost 173 days. So remember, hospice is a prescribed benefit, recommended benefit for 180 days. So you can see where the cap amount gets you right into that balance of 172 days. The interesting thing is, if you live in a low wage index state, the cap amount stays flat for the whole country.

So if you live in New York City, California, and San Diego, West Palm Beach, Miami, you know, these higher, expensive areas, the dollar value to get paid per day is more, but the number of days you can treat those patients as well, because the cap amount is a national cap amount, it doesn't wage index or fluctuate.

A patient in South Carolina may get 200 days before they hit cap, or a patient in California may only be 155 days before they hit cap. And so you have to pay attention to this really closely and manage it. Another thing in the rule that was, I thought was super interesting is this 5% max cap adjustment.

So the maximum, essentially, cap adjustment that they can make by law is 5%. So even though you're getting at 2.9% and they're going to look backwards on this, if the max is 5%, you may get a little bit bigger or you may get less. So it's all based on your wage index and how the government sees that community which you live or serve your patients in.

And so you need to pay really close attention to the wage indexes based on the counties. Interesting. The 2.9% increase is only uh, less than the, 3% or 3.2% CSI that's going on in the world today. So, you know, the cost of living is going up by 3% but we're only going to 2.9% raise. So we have to figure out how to manage this.

Jay:
So obviously the final rule included the new HOPE tool which is a pretty big shift from the HIS measures traditionally have been administered in the hospice space. How does this tool differ from the HIS measures and the expected outcomes that we're going to see focus on the outcomes measures versus the process measures that we're going to see utilizing this tool.

Tom:
Yeah, so let's explain it. So, hospice outcomes and patient evaluation tool. It's called an assessment tool. My whole career since 2005 when I started playing in this field, hospice has always said I hate having OASISs. Home health uses Oasis hospice uses HIS. Everybody that I've ever talked to said that We're not home health don’t talk to us like were home health. My opinion is this is becoming more like an oasis. So these key metrics that they're doing are going to require us to do specific segments and specific documentation of an assessment tool. I'll walk through kind of what they are. So, social, demographic information, that's like age, gender, race, ethnicity, demographic location, where do you live, role in that role, those kind of things, and they're really going to look at your diagnosis.

So primary and secondary diagnosis, including conditions, put a flag on that one. I think that one's going to be a little bit of a challenge for us, and we'll come back to that symptom impact assessment. So, this is assessing the impact of things like pain, shortness of breath, nausea, other, uh, distressing systems, behavioral health, depression, dementia, Alzheimer's, those kind of things, and then evaluation of severity and frequency of the symptoms.

There's going to be specific physical assessment questions. You're going to have to answer an ongoing basis in order to say, is the patient approving or not improving from these things, and are we controlling it? Right. Last thing that the government wants is nana to have a lot of pain. Are we controlling that pain?

Are we giving her the right amount of medications or the right therapies or the right programs to manage that pain? Skin conditions is a big one, but they're really focusing in on that intimate death. So, assessment assignments indicate the patient may be nearing the end of life. There's lots of tools out there like me using and other tools that are looking at it, but they're going to have questions around that want to be able to know exactly when that's starting to happen.

So you'll have to document that correctly and then timely follow up for pain impact. This is more around. We noticed the patient had pain, and then there was a follow up visit occurred within 48 hours, identifying moderate or severe pain. So I can envision, does the patient have pain?

Yes. How severe is the pain? It's extremely severe, moderate, whatever. And then they're going to say, did you do a visit two days later? Within two days later, are you checking on that pain? And the other one is timely follow up for non pain symptoms. So that's whether a follow up visit occurred 48 hours to identify moderate or severe non pain symptoms.

And the last one is preferences regarding care goals, advanced directives or other end of life decisions. Are we talking about end of life decisions? No. CPR, DNR, those kind of things. Those are called advanced directives. And do we have those documented and once you document them, if they establish them in the EMR, but you also have to establish them in the home case.

Somebody calls 911 and is having trouble breathing, they call 911 and the ambulance comes, you want to be able to see visually on the refrigerator, front door, wherever they put them, that Nana is DNR. Nana's no CPR. That's her desired outcome, and they'll work on it. Why are these so going to be so important?

One, we have to train hospice nurses in how to answer these questions appropriately. Make sure that we're following the documentation guidelines that CMS put out in their fact sheets. These are going to require different assessments. So think about it as you are in your EMR and you notice that a patient has pain, I can see validations requiring you to go schedule a visit within 24 hours or 48 hours from that patient's pain.

If it's one of these other non pain symptom pack, we also have to reassess these often. So today in most EMRs, we did the HIS questions. Back in the day, it was usually on the start of care visit, the first visit that we did, or on a recert visit, which was when we started the patient from a 90 day or 60 day episode.

These are going to require. Every 14 days. So, you're going to have to create a new service code or some kind of a way of tracking these in your EMR in order to make sure that your clinicians are simply reminded or validating that they answered this question again. And then I see software tools being created to track these.

Right. So Nana was severe pain, now she's moderate. We did these visits, and so how do we analyze that? And so Nana has skin conditions of a wound and 14 days later we have to assess those. So it's going to add additional documentation to the requirement, but it's also going to add additional level of training and effort that you're going to need to do for your clinician first time.

This has really been this big of an impact where they said every 14 days you have to do it. Notice the 14 days is probably following close to the IDG, so they want the physician to be looking at these. So I would make sure that I'm documenting these in my physician IDG notes each month to make sure that we're doing that as we do that two times a month.
So they introduced the hospice update visits, which is during visits, healthcare providers will assess the changes of the patient's condition, symptoms, or care needs. And that's every 14 days. You also have to collect data up on discharge. So my opinion, government's looking at this. If the patient's alive, discharge or revocation, this patient, they want to, you know, kind of do curative care, then they're going to ask for you to collect this data upon discharge.

And then, also during the follow up symptom impacts. So non pain or pain symptom impacts, the 48 hours, there's going to be a lot of additional documentation that's going to be required in hospice in order to manage this. Every time the government comes and says they're going to collect data, they're collecting data for a reason.

They're trying to solve a problem in the industry that they've seen, or they're trying to collect data so that they can make impacts in the future. So super important to follow the rules. It's super important to make sure your nurses are trained. It's super important to make sure that documentation is appropriate, and the nurses understand how to do it.

Jay:
Going from process measures to now outcomes and the patient experience, I think, is a pretty big seismic shift there. The real time data collection versus kind of a set point in time on the data side, I think agencies are really going to have to retool to be able to provide that timely.

And then, of course, the fact that you're going to care processes and protocols before, and now you've got to go through a lot more specific data emphasizing patient families, emphasizing all the physical, emotional, psychosocial needs, too. So quite a big shift there. So Tom, what's the timeline on the implementation of the HOPE tool and when should agencies expect to be ready and prepared for that to be operational?

Tom:
Yeah, so remember, in hospice, the fiscal year is October to September. So the hope tools start being implemented in the fiscal year 2025, which begins October 1 of 2024. Different than home health, it's good that they do this, right? Hospice gets their impact and change and goes live in October, and then home health gets their change in the November 2, it gets implemented, and by January 1.

So the HOPE tool assessments will begin to be collected October 1 of 2024. So we're in August, August 7. So you have elect six weeks, get ready seven weeks. And then the initial reporting period for 2025 will be during the three years hospice will collect and report data using the HOPE tool.

Fiscal year 2028 is when the new quality measures will introduce with the Hope tool will begin to officially be reported out. So this is going to grade you on. How well you take care of patients with pain, how well you take care of patients with symptom management and those kind of things.

And then it will probably come with reductions in fees. If you're not doing a good job or star ratings or something of that nature, they're going to publicly report the hope outcomes. So it's going to be really important that you start, you get this right, you start collecting your data, and then you continue to report in 25 and 27.

Essentially, this is your report card to CMS. They're going to look at this very closely. I'm sure there's some kind of database that they're going to run, be able to look for the bad actors or the people that aren't following the rules are doing the right thing. So super important that we get this right.

Super important that we follow the rules and train all the staff.

Yeah. And I think people may falsely just kind of see that October 2025 implementation rule and forget, well, that you're going to actually be reporting in October 2025 of your performance starting in October of 24. So just a key takeaway that the time is now to start making sure your processes are aligned and your data Reporting is you've got some time, but need to act quickly.

And CMS published the goals of the hope tool, which I think is interesting when you look at the goals. What did they say? Why are we doing this? Why are we making these changes? And it's something that CMS always does really well. They always tell us the why, kind of publicly of what they're doing.

So the why is they want to do comprehensive patient monitoring. And they believe that by collecting multiple points during the hospice stay, aims to provide a detailed understanding of the patient's condition and care needs. So how sick is Nana and in what are her care needs? They also believe it's going to be an improvement in care quality.

So by forcing us to assess the patient in the structured data formats and then have to report that, it'll force the agency to want to assess those until you react to them. And then the last thing they said, and this is the one that I always giggle at, is the enhanced reporting and accountability.

So data collection reporting requirements enhance transparency and accountability in the hospice care. And so that's the area where, you know, they're going to grade you and then they're going to, they're going to say by provider number, how well are you performing? It's okay to perform. We know that our hospitals are going to perform great, and so it's okay.

And I, I believe that when you get these standardized assessment tools out there, you force accountability and transparency for sure. But you also ensure that we're getting paid to take care of data, so let's make sure that everybody's doing it correct.

Jay:
That's great. So we talked about the quality data submissions and that being real time and not just a point in time, and agencies will really face a significant penalty with that, a financial penalty with negative 1.1% update. So what do you think hospices should do to ensure compliance with this? And what challenges do we see with conforming to these new standards?

Tom:
Yeah, it's definitely a challenge. So, quality data submission requirement. This is under the HQRP or the quality Reporting program. Hospices are required to submit this data set which your EMR should create for you, and then you submit this data to the government and you have to do it on a timely basis.

If you don't submit your data, then they're going to cut you by 1.1%. If you like not to submit your data, then they're saying, hey, you, apparently you don't want to be a part of our quality program. We're not going to pay you as much because we're paying the hospices that are part of the quality program.

Sometimes those systems are down or whatever. There's ways to adjust all those, but you have to comply with this. So you got to put a process in place that makes sure that they're doing this. You got to put checks and balances in place. This is somebody's job inside the organization to submit this data.
Someone needs to tell you every month that they submitted their data, and you need to have checks and balances there that said that data was submitted and accepted. And so make sure that you're doing that. It's super important. The other side of it is when you're doing an acquisition, you want to make sure that that agency has submitted their data, and a lot of times these will impact you for years.

So, if it's in the middle of a year and you haven't submitted your data, the data requirements for reporting is a negative 1.1% cut. But if you didn't submit in the last two years, then as you're trying to evaluate the business and what is the amount of revenue that that customer's going to make a 1.1% cut, just because we feel the center data is not good, and there's a lot of them out there.

I was looking in California last week of the STAR ratings for all of the hospices, and there's hundreds that haven't submitted data. And so these guys are just essentially taking a negative pay reduction because they fail to submit their data. So please make sure you look at that.

Please make sure you have a program for it. Please make sure you monitor that program. It's the requirement of the CFO to make sure that that data is getting submitted. The clinical officer probably submitted it, but the CFO needs to be validated.

Jay:
And I would say, too, if you need help navigating that submission, especially with the changes, please call us. We're happy to help with our consultants and make sure, you don't want to miss out on that because you weren't able to report. So it needs to be timely and if we need to help, please reach out.

Tom:
Yeah, for sure. We build, you know, hospice quality programs all the time, so, I mean, the data is going to be important, right? You want to make sure that you're gathering the right data, analyzing the right data, it's not just about submitting the data, it's about putting a program in place.

The government's just not asking to give them data so they could tell on yours so they can evaluate you. They want you to put a program in place so that you can manage this data, and so you're taking care of patients quality, and that's the real purpose of it.

Encouraging compliance is a term they used in the rule. I love that term, encouraging compliance. It's essentially saying, we're going to force you to try to be compliant, but we're just encouraging it, and then we're ensuring high standards.
The goal is to make sure that hospices are doing the best possible care for their patient. It really is ensuring standard. And then of course, they're creating a database with all this data driven improvements. So how do I pack the future? How do I impact. 28, 29, 30 and so on.

How do I keep this benefit available? We need data in order to do that. And so this is the government's way of collecting data so they can analyze the data. It's part of the program.

Jay:
You made a great point there, Tom. Submitting the data is one thing, to avoid the penalty, but really making those operational changes to improve the patient care is really what they're after. So considering those changes, you know, what operational adjustments do you think hospices need to make to align with those new requirements?

They may affect staffing and resource allocation. So how do those changes in the rule affect the operations of a hospice agency?

Tom:
It's super interesting when you, when you start really looking at, you know, what happens in a hospice business. From the time I get a referral to the time that, you know, the patient either passes or discharges, these changes are going to be pretty impactful, going to require you to have better capacity planning.

You're going to have to make sure that your nurses understand that when that patient has pain, you have to be back out there within 48 hours. Or if they have down symptom problems, you're going to have to be out there in 48 hours. You got to figure out it.

And hospice has historically never run a productivity model. They've more done a case management model, and I think that's becoming more and more of a challenge. Timeliness of care is super important. So how do I get someone to the home? And it's not just timeliness of care. On the start of care, the referral comes in via the portal.

Today, you need to. To admit that patient as quick as possible. And so we spent a lot of time working with intake teams around automation as well as impact of that. And so how do we cut out all the slowness in the process and make sure that we're getting a nurse to Nana's home as quick as possible?

Just explain that in a real social environment. Nana just elected hospice and it took us five days to get there. And so, a lot of times we just change the messaging and we can get there quicker. We want to get there as soon as we can. Nana's had a bad day, She's home now, knows she's dying, and we need to get to her as quick as possible and start a care plan. We also need to manage that family.

What about the bereavement, the social worker that needs to go out and start planning? You know, this is an end-of-life situation, so it's serious, but making sure that we're quick and fast on that is going to be super important.

So optimizing intake, super important. Optimizing schedule, super important. Managing capacity, super important. So we have to figure out how to go quicker, faster, better, but also stay compliant and make sure that we're getting there timely, doing a good job on the quality of documentation. As that documentation start of care comes in.I skipped over the diagnosis code one, but I want to jump back to that. We have to figure out how to code these patients correctly and continuously code them as they progress through their disease. The diagnosis code should change and the government's looking for you to change them or if a wound is progressing, and so doing a better job of coding.

Historically, lots of hospices that we've looked at do one, two, three codes. They put a couple of co morbidities on there and they let it go. We're seeing now 15, 18, 20 codes in home health, and I think hospice is going to get there as well. You need to code the reason why the patient's on hospice and all the other supporting diagnosis codes of that, and so making sure eligibility is correct and we're documenting hospice eligibility.

We're making sure that we have our CTI in our face to face. We're making sure that our medical director continues to document towards the decline of the patient is super important, and it's where we're seeing a lot of the TPE. That's where we're seeing a lot of the ADR's come in.

Where people are getting on level two, level three and level fours is because they're not doing a good job of documenting the decline of the patient and the reason why the patient is hospice eligible. Think about that as you're doing your physical assessment questions and your documentation, as well as training your medical directors.

It's going to be super important to make sure the medical directors understand this hope tool, an area that we normally don't do, or hospice physician. So we need to make sure that they understand it, so they're documenting towards it as well.

Jay:
Significant changes in operations. And you can't just change behavior, although that's a big portion of that, without addressing kind of the technology and data and other tools out there that you would recommend people considering right now in light of the new rule.

Tom:
It's a great question, Jay. So, I mean, to start with, all of you knew I was the founder of Muse Medalogix product. Now that we sold to Medalogix and, that tool has been adopted by the majority of hospices. It's an unbelievable tool. It's so accurate and reviews of physical questions and then predicts the length of stay of Nana.

But it also gives just complete visibility of what's going on with the patient and the secret sauce. There is the risk for how likely is Nana to pass away? And we're going to do things different for Nana. You know, why would we refill 30 days worth of opioid medication for a grandma who has seven to ten days left to live?

Or why are we doing two visits in the last seven days when we should be doing. Seven visits in the last seven days. Why is Nana passing away and we don't have a social worker there? Nobody more important than a social worker or chaplain at the end of life, right?

You're going to get ready to do a transition here, and then who's going to manage the family? We're talking about real life scenarios here. And so, tools like Medalogix Muse are tools that give you visibility into that. If I'm a branch leader, a clinical field staff supervisor, DOM, whatever you call me, and have 300 patients under my census, how do I know which patient's most important for me to go look at versus the next one?

How do I manage my day and to go see the right patients, or make sure that my caregivers are doing the right things for those patients? And so I have responsibility to manage that. And having tools like the Medalogix muse product would be really good for you. Managing caps is going to be a real problem.

How do I know what the length of stay is on a patient that's coming in? There's another tool out there called Hospice Dynamix. We partnered up with them, at Muse and at Maxwell, because we believe that that tool is really going to help you manage cap and make sure you're calling on the right kind of patients and visiting the right kind of patient and admitting the right kind of patients with that hospice eligibility.

It also manages compliance. So as we look at these patients and the long length of stay patients, how do we make sure they're hospice eligible? So that's another tool. And then, just as you get into optimization and scheduling efficiencies and bereavement and some of these other things, the Maxwell team is really focused on this area, and it spent a lot of time and money building tools like NOTIFYnana, the number one complaint in hospice still on the HHCAHPs survey.

I never knew when you were coming to see my grandma, you would come three times a week. That's awesome. But I never knew when you were coming. So NOTIFYnana. That's what we built. That allows us to do scheduling and appointment reminders, also, uh, allows you to survey, how well did my nurse do?

How well did my social worker do? Do you have any complaints? If you have a complaint, I want to fix it. Right. Maybe I sent you a female caregiver and you wanted a male, or a male caregiver and you wanted a female. Those are simple things I can fix.

Or maybe I sent somebody that's Allergic to Animals, and I have two cats and a dog. What do I do with that. And so how do we satisfy the patient's needs? But we have to know that information right away. And so we do surveys, we do family reminders, and there's other tools out there.

I can't be there every day. There's no way that I can afford to go see the patient every single day for 150 days. I will lose money. And so there's other tools, like nanaCONNECT that have been done. It says, Nana, how do you feel Today compared to yesterday?

Or, Nana, are you in Pain Today? If Nana says yes, then when you pick up the Phone and call her, we, instead of her calling 911 and revocating getting off our service, we simply manage it through very lightweight, inexpensive text.

I'll challenge anybody out there that says, our elderly patients don't have cell phones anymore. They all do. It's probably the only positive we got out of COVID is everybody adopted technology. And so instead of spending $150 and putting a blood pressure cuff and monitor and a scale and all this stuff in Nana's home, which she doesn't want, let's just communicate with her via text message.

The nanaCONNECT product allows you to quickly and easily in an automated way, see how all your patients are feeling today compared to yesterday. And then last, you know, we have to figure out how to pay for all these tools. And one of the ones that's paying for most of them is nanaBEREAVEMENT.

nanaBEREAVEMENT is an automation of the bereavement process. So, historically, we would send letters or Nana's family members after she passed away. And those letters cost about 75 cents per letter by the time you do print, roll, fold and mail. And we're sending eight to twelve letters, to three to four people that are assigned to Nana's bereavement.

When you get a letter, if I want to get off of bereavement, I don't want the letters anymore. I have to call the office and do that. And then when was the last time that anybody had a letter where they actually went and typed in your website? And so nanaBEREAVEMENT will actually text you the message, but also give you links to a website, which then gives you the resources to go back to your hospice, give you the ability to refer a friend, give you the ability to sign up for community bereavement, give an interaction video from your medical director or hospice physician or CEO that's supportive around, you know, grief and mourning.

And so how do we give you more tools than just send you a letter or a postcard? And that's been the goal, and so it's been widely adopted across the industry. We're the first ones to put out a text based bereavement program that's automated. And so bereavement is you don't get paid for bereavement, it's part of the hospice benefit, and you have to do that for twelve months after the patient passes.

And so that can be very costly and expensive. We see ROIs on this at over 100% because we can do it through automation and we can do it very inexpensively by texting the patient. The last tool that I think's out there that's gonna be really wide adopted for hospices, create a tool called Caregiver Accelerator.

And Caregiver Accelerator was created in the effort to manage staff. Where are they? How many visits do they have? What's going on with those visits? How do we make sure that we're not moving visits? How do we get nurses to productivity or get their case load right? It's simply about, you know, we're paying someone a salary, or even if we're paying them per visit, how do I make sure they have the right amount of visits, that they're addressing those visits appropriate and timely, and give the schedule tools to manage capacity.

Right. If I have to wait a day to call my nurses to figure out who can take another start a care visit, I just made Nana wait 24 hours before she can get care. And so how do I manage capacity? How do I know if I can take another patient or not take another patient?

How do I know the sickest patients versus the less sick patients, how do we care for them? And so Caregiver Accelerator really streamlined that and made it efficient. Essentially a giant dashboard that shows you all of your caregivers and the status of every single visit in the count of their productivity points or caseload as a tool not only for scheduling, but for capacity planning for CEO's COOs that are trying to manage their staff.

It's a huge issue in our industry, making sure that the right nurse is at the right patient house at the right time.

Jay:
Yeah, Tom, it can't be underestimated how important communication is, especially for the patient and the family caregiver experience, too. So it's nice to see that there are things pushing towards that focus in not only the data collection, but in how you engage with these families. And the involvement of the patient and the family in hospice is so vitally important.

So obviously, a lot of these changes are coming in this fiscal year 2025. But let's think about the future and what we envision. Kind of the long-term perspective from CMS changes on the hospice industry. What innovations or improvements would you like to see in the future?

Tom:
Great question, Jay. And all of you know that I'm a AI and machine learning - I won’t call myself an expert, but an innovator. You know, Muse was the first product that ever-touched AI. We were doing that way before Chat GPT and all these LLMs and all that were out there.

But I truly believe that. That the future is around LLMs. How do I use large language models not to hallucinate, but to summarize, how do I take a 200-page referral package of Nana's discharge disposition, her history of physical and all those things? And how do I summarize that for you?

If your expectation is that your nurse is going to go read that entire documentation, time yourself and go read 200 pages and skim through 200 pages, it takes too long. And so, the industry that are out there right now, Medalogix, has built some, we're building some that will manage those summary for those patients, show you the diagnosis codes, show you that Nana had a fall, show you the inpatient events, and make that simpler for your nurses.

And so I think the innovation is how do we make this job easier? Already the hardest job in the world, hospice, is you're dealing with death and dying constantly. People love it and they're angels for doing it. But how do we make their job easier? How do we make it simpler for them to do their documentation?

How do we summarize this data for them? How do we use large language models to make sure we're not missing things? I'm not saying write all your documentation for you. I'm not saying take away the nurses subjectivity and objectivity around the patient. But how do I make it easier to go find stuff?

I think that's an area that I really see people adopting. And then you have to figure out how to automate and become better and faster. The days of just adding people to the process is broken, and we can't keep doing that. We don't have enough people. And so patients are not getting care because hospices can't take them because they don't have the capacity and it's really sad.

And I always put that into perspective. If that was my grandma, and someone wouldn’t take care of her, well, I'd have to go beg 20 people to take care of her. It's her benefit. She earned it. The Medicare benefit that she earned as she worked her whole life.

Those are the areas I think we're going to really see a lot of focus and innovation on making things easier, making things faster, making things more compliant, using these large language models or AI to help us with that.

Jay:
I think that's great, Tom. And these changes are simple, but impactful. I think there's a lot of implications for the data side, for the people side, and for the process side. So, I'm excited to see these changes and how everybody navigates to them. And has to do it quickly.

So, we've built a lot of our processes and optimizing those very things, technology, the people to process in that space. And we've got a lot of great consultants that have been caregivers in the industry and hospice specifically. And so, we'd love the opportunity to talk to people about how do we address those issues because it really touches all those areas, data people process and optimizing those and make sure they run efficiently and smoothly and that we're reporting back those activities.

You know, the data affects the people, which affects the process. And so, you know, I'm excited to see these changes and how the industry reacts to those, too. But thanks for that perspective, Tom.

Outro:
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Unpacking the FY 2025 Hospice Payment Final Rule

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