Individual

I oppose the elimination of The Budget Neutrality Adjustment Factor. The impact of eliminating it will be to decrease the quality of care offered by hospice programs, limit access to hospice programs and subsequently increase the overall cost to the Medicare to care for patients at end of life. Additionally this action is premature and poorly timed in light of other changes that CMS has made and will make in regard to hospice programs. Over 80% of the counties in the United States will have reduced payments to hospice programs. This will weaken many programs – especially the not-for-profit programs who offer so many services for their communities. Treasure Coast Hospice will be especially hard hit. The cost of living in Florida and along the Treasure Coast is higher than other parts of the country. Since the hurricanes of 2004 and 2005 Florida has suffered with higher home insurance costs and higher property taxes. Now with higher gasoline prices healthcare professionals are less mobile. There is pressure to pay higher salaries as staff shortages abound as more seniors needing more care move to Florida. The elimination of the Budget Neutrality Adjustment would have a negative impact on Treasure Coast Hospice and the quality of care that we provide since we would not have the revenue to pay competitive salaries for healthcare professionals and offer the high level of services we currently do. Fewer patients will avail themselves of hospice services because they will be unaware of hospice services. We conduct education to providers (doctors, hospitals, and nursing homes) and to the community in a variety of forums about hospice care. The result is increased awareness of hospice services which translates into increased access for hospice-appropriate patients. Unfortunately, less revenue would force us to reduce community outreach and education. Fewer patients would then access hospice services. The net effect for Medicare would be increased costs, since patients who would otherwise receive hospice services will be cared for in hospitals. Treasure Coast Hospice manages its financial resources carefully. We keep administrative overhead to a minimum and we maximize the ratio of professional caregivers to patients so that they receive the highest level of compassionate care possible. Our margin on operations is less than 1% and that money is reinvested in the organization. I recognize that the Hospice Medicare cost has increased dramatically in the last few years. Consider Medicare costs without hospice. Hospice care reduces the overall cost to Medicare for patients in the last months of life. Eliminating the Budget Neutrality Adjustment Factor is premature and hinders hospice programs as they try to comply with new CMS regulations. First, CMS has just published new Conditions of Participation. It will cost hospice programs more to comply with the new CoPs. Second, CMS is gathering data about how hospice programs deliver care. Ostensibly the purpose of this data gathering is to change the method of payment to hospice programs away from per diem payments. The cumbersome data gathering is very expensive for hospice programs. Treasure Coast Hospice has had to hire four additional employees who job will be to gather and report this data to CMS. Third, as the Baby Boomer generation reaches retirement and beyond, hospice programs offer the best way to provide high quality, compassionate care in the last months of life at the lowest cost possible to Medicare. It is in the country’s and CMS’s best interest to have strong viable hospice programs ready to take on the increased patient load we can expect in the next twenty years.