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June 26, 2013 Submitted Electronically Marilyn Tavenner, Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS–1449–P P.O. Box 8010 Baltimore, MD 21244–8010 Re: File Code CMS-1449-P Dear Ms Taverner: LeadingAge appreciates the opportunity to comment on the Proposed Rule, Medicare Program; FY 2014 Hospice Wage Index and Payment Rate Update; Hospice Quality Reporting Requirements; and Updates on Payment Reform. To expand the world of possibilities for aging, LeadingAge members and affiliates touch the lives of 4 million individuals, families, employees and volunteers every day. The LeadingAge community (www.LeadingAge.org) includes 6,000 not-for-profit organizations in the United States, 39 state partners, hundreds of businesses, research partners, consumer organizations, foundations and a broad global network of aging services organizations that reach over 30 countries. The work of LeadingAge is focused on advocacy, education, and applied research. We promote adult day services, home health, hospice, community-based services, PACE, senior housing, assisted living residences, continuing care communities, nursing homes as well as technology solutions and person-centered practices that support the overall health and wellbeing of seniors, children, and those with special needs. LeadingAge will focus its comments on the portions of the Proposed Rule dealing with the use of non-specific symptom diagnoses and Mental, Behavioral and Neurodevelopmental Disorders’’ ICD–9–CM Codes, the Hospice Quality Reporting Program, Public availability of data collected, and the Hospice Experience of Care Survey. We also will be commenting on the update on Hospice Payment Reform and Data Collection and Site of Service Adjustment for Hospice Patients in Nursing Facilities. Diagnosis Reporting on Hospice Claims: ICD–9–CM Coding Guidelines and Use of Nonspecific, Symptom Diagnoses We agre