Letter from Amy S. Tucci, CEO and President

August 30, 2011
Centers for Medicare and Medicaid Services
Department of Health and Human Services

Subject: Hospital Discharge Care Coordination

File code: CMS-1524-P

To Whom It May Concern:

Hospice Foundation of America is pleased to submit comments to encourage CMS work on Hospital Discharge and Care Coordination. CMS recently issued proposed changes to the Medicare Physician Fee Schedule (which includes several practitioners paid by Medicare). The proposed rule provides CMS an opportunity to work toward coordinated care for Medicare beneficiaries. CMS is specifically seeking comments on whether physician activities should strive to ensure effective care coordination surrounding a hospital discharge, including whether hospital discharge care coordination services are appropriately valued.

In 1990, Hospice Foundation of America (HFA) expanded its scope to a national reach and provides leadership in the development and application of hospice and its philosophy of care with the goal of enhancing the U.S. health care system and the role of hospice within it. HFA meets this mission by conducting programs of professional development, public education and information, research, publications and health policy issues. Our programs for health care professionals assist those who cope either personally or professionally with terminal illness, death, and the process of grief, and are offered on a national or regional basis. Our programs for the public assist individual consumers of health care who are coping with issues of caregiving, terminal illness, and grief.

In 2009, CMS awarded HFA a grant to develop and disseminate information and education on hospice care, special populations (i.e. rural communities, veterans at the end of life, persons with advanced dementia, caregivers) and the Medicare Hospice Benefit. HFA undertook the challenge and developed an online Hospice Information Center (www.hospicefoundation.org/infocenter) with multiple products and resources to help consumers and professionals access correct and current information about hospice, funding sources, the special qualities of hospice care, and helping professionals and consumers alike to cope with and manage the often challenging tasks that come with dying and death.

Every day HFA interfaces with consumers and professionals involved in hospice and palliative care, and end-of-life situations. As stated in this CMS Special Opportunity for Comments, the current U.S. health system often fails to meet the needs of frail elders and their caregivers, because hospital discharge is often rushed and responsibility is fragmented, with little communication between settings and providers.

The latter is one of the points HFA would like to provide comment. Patients who enter hospice are typically older adults with terminal conditions who come to hospice care in the last few weeks of life.  Many hospice patients are Medicare beneficiaries who transition into hospice care from a hospital discharge. When coupled with a rapid hospital discharge and poor coordination among providers and settings, the transition into hospice care is often fraught with hurry, overwhelming emotional and mental grief, and feelings of abandonment on the part of patients and families, and problems with discharge. The hospital discharge and transition into hospice in the community setting needs special care coordination efforts to help ensure a more seamless and dignified adjustment.

HFA receives many calls, emails and comments from hospice professionals, hospital case managers, and patients and families on how difficult this transition is—from both sides of the discharge. When hospital practitioners discharge patients into hospice care, we have learned that it is doubly difficult, because many practitioners are challenged in communicating about dying and death and coordinating a discharge of a Medicare beneficiary who may be hesitant about entering hospice care and giving up on curative treatments. Also, many patients who enter hospice late in their disease state can be considered frail elders. Many of the communications that HFA has with patients and families is how difficult the transition into hospice is and how quickly hospital practitioners want it to happen. Family caregivers are often feeling overwhelmed and rushed when stepping into a major caregiving role at the end-of-life.

HFA would recommend and encourage CMS to undertake regulatory and developmental work on continuity and standards that would help very ill individuals and their loved ones/caregivers that must transition in the health care system, often from hospital to home with hospice care. And hospice care is delivered to the patient at home—wherever home is…a private residence, a nursing or assisted living facility, or a residential hospice. HFA believes that the work CMS would undertake to improve hospital discharge and care coordination for frail elders and those with terminal conditions would greatly help make the transitions across health settings more seamless, timely and effective for both the practitioners and beneficiaries and their loved ones affected by hospital discharge and the important need for care coordination.

Sincerely,

Amy S. Tucci
CEO and President
Hospice Foundation of America
1710 Rhode Island Avenue, NW
Suite 400
Washington, D.C.  20036
Tel: 202.457.5811
www.hospicefoundation.org