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How to Establish a Palliative Care Program

Medicare

Select:
Community Hospitals
Academic Hospitals
Subacute and Skilled Care
Custodial Care
Ambulatory Outpatient Care
Home Care
Hospice Care

Medicare is the federal health care insurance program for eligible people. People are usually eligible if they are over age 65, disabled, or have end-stage renal disease. It is funded by a federal tax on income that is paid partly by the employee, and partly by the employer. Medicare is divided into 2 parts: A and B. Part A covers hospitalization.

Financing Community Hospitals
Medicare pays hospitals an amount of money for the total hospitalization of a patient after the patient is discharged under the Diagnosis Related Group (DRG) system. The associated amount of money for each DRG is determined by the Health Care Financing Administration (HCFA) based upon average lengths of stay and average costs associated with the DRG.

The DRG payment is determined in the following way. After the patient is discharged, the patient's chart is abstracted for coding. The hospital determines the DRG code that best fits the chart. If a patient is in the hospital much longer than the usual range of days for that DRG, the hospital may code for an outlier status.

Since the hospital receives a single amount of money for a given hospitalization, it should be obvious that a hospital is not financially rewarded for keeping patients for longer stays, or engendering higher costs.

Hospitals report their charges and cost: charge ratios to HCFA on a regular basis. An individual hospital may receive adjustments to their DRG fee structure based on the overall number of Medicare patients they care for (disproportionate share adjustments).

There is no DRG for palliative care. There is an ICD-9-CM diagnosis code for palliative care that carries no reimbursement. The code was instituted as a research tool to help identify services in hospitals which included palliative care. (Cassel CK, Vladeck BC. ICD-9 code for palliative or terminal care. NEJM1996;335:1232-4. Unfortunately, because there was no reimbursement associated with it, few hospitals used the code. Little useful information was obtained.
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Financing Academic Hospitals
Under Medicare, academic hospitals receive additional reimbursement for their direct and indirect costs of education.

Direct costs. A hospital receives a sum of money for each resident being trained in a program approved by the Accreditation Council for Graduate Medical Education (ACGME). That sum includes the salary and benefits for the resident, as well as the physician faculty that must be supported to educate that resident. Recent adjustments to the federal fee schedule have rewarded hospitals for training primary care physicians. Payments for specialty training have been discounted.

Indirect costs. This is designed to offset the additional costs to a hospital from having physician trainees such as additional diagnostic tests, therapeutic procedures, and hospital days that characterize physician training. The actual amount an individual hospital receives is determined under a complex formula. That formula includes both the reported costs of education as well as historical precedent.

The amount of money an academic hospital receives can also be adjusted for the severity of illness and indigency of its patient populations.
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Financing Subacute and Skilled Care
Medicare Part A pays for some types of subacute inpatient care. Subacute care settings are characterized by lower acuity than acute care hospitalization. Fundamentally, this means that nurse-staffing ratios are expected to be lower than that in the acute care hospital. All are characterized by a rehabilitative and short-term focus.

There is a cap of 100 days of skilled care following an acute care hospitalization.

For skilled care in nursing homes, Medicare is phasing in a new prospective reimbursement system that is similar to the DRG system for acute hospitalization. It is called the Resource Utilization Group (RUG) system. The Minimum Data Set (MDS) will determine rates for each patient by placing them in one of the 44 RUG-III groups. The higher payments are connected to intensive rehabilitation services, such as physical therapy following orthopedic surgery.
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Financing Custodial Care
Medicare does not cover custodial care.
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Financing Ambulatory Outpatient Care
Physicians (and some other caregivers) are paid under a fee-for-service system for the care they give to Medicare Beneficiaries. Beyond these payments under Medicare Part B, Medicare does not pay for outpatient ambulatory care. Physicians pay for all of the costs of running their offices from their fee-for-service revenue. Some non-physician services can also be billed in a fee-for-service fashion.

Medicare does have some special programs that fund outpatient care, eg, The Program for the All-inclusive Care of the Elderly (PACE). They typically serve specific populations, eg, the elderly and are limited in number.
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Financing Home Care
Medicare covers home care services for patients that meet 4 criteria. They must:

  1. need intermittent skilled nursing care or physical therapy or speech language pathology
  2. be homebound
  3. be under a physician's care plan
  4. receive services from a Medicare participating home health agency.
The definitions of the first 2 criteria have evolved to a more restrictive interpretation in recent years. However, they still must be interpreted for each individual patient. Home-bound means that the patient must be at home except to go out for doctor's visits. Skilled nursing need means that the need requires the skill level of a registered nurse.

Once these criteria are met, a range of services are available. That range of services can include home-making and nurses aide services, social work, physical and occupational therapists, medication administration and management, blood drawing for laboratory tests, blood transfusions and physical assessments and some durable medical equipment (subject to 20% copayment).

Home health companies have been reimbursed under a fee-for-service system. However, in an effort to reduce payments, Medicare is making a transition to a prospective payment system for 60-day periods of home health care. At the current time, home health agencies are required to report on the health care assessments and needs of their patients, along with their associated costs. Based on this information, the final rules for the new system will be implemented.

The focus of home health care under Medicare is increasingly on short-term interventions with a rehabilitative focus. Many would say it is increasingly difficult to use the system to pay for the costs of home care for the chronically ill with a poor prognosis.
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Financing Hospice Care – Medicare Hospice Benefit
In response to the enthusiasm of early pioneers, the Health Care Financing Administration funded a national demonstration project beginning in 1979. The purpose was to establish a standard definition of hospice care and assess cost effectiveness.

Based in part on the experience of the National Hospice Study, the 1982 Tax Equity and Fiscal Responsibility Act (TEFRA) established the Medicare Hospice Benefit (MHB). It became effective the following year. It was the first use of a prospective payment system by Medicare. Today, it continues to be the most comprehensive benefit for end-of-life care available.

For eligible patients who elect to enroll in the Benefit, a Medicare-certified hospice program assumes responsibility for the complete plan of interdisciplinary care for the patient and family related to the patient's terminal illness. This includes a wide range of covered services.

In return, the hospice program receives one of 4 fixed reimbursement rates per day (the Perdiem) according to level of care: routine home care, continuous care, general inpatient care and inpatient respite care. These rates cover all of the services that are covered under the Benefit.

For conditions unrelated to the terminal illness, the patient use their regular Medicare coverage.

The Medicare Hospice Benefit provides two benefit periods of 90 days each, followed by an unlimited number of 60 day periods.

Resource:
HCFA: The Hospice Payment System

Next, consider Medicaid.

CAPC Resources:
Additional resources on "Financing US Healthcare"

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Help develop CAPCManual. Send your comments, questions, suggestions to: fferris@sdhospice.org
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CAPCManual Attribution:  von Gunten CF, Ferris FD, Portenoy RK, Glajchen M, eds. CAPCManual: How to Establish A Palliative Care Program. New York, NY: Center to Advance Palliative Care, 2001.   © Center for Palliative Studies, San Diego Hospice & Palliative Care, San Diego, CA and
The Department of Pain Medicine and Palliative Care, Beth Israel Medical Center, New York, NY, 2001

Permission to reproduce for non-commercial educational purposes with display of attribution and copyright is granted.
Last updated: February 20, 2002

Elements
Select section:
Basis, Context, Components, Case Examples

•  Basis of Palliative Care Practice
      Palliative Care Definitions
         Historical Definitions
            WHO
            Oxford Textbook
            ABHPM
            NHPCO
         Palliative Care
         Applicability
         Application to Patients at Risk
         Differences–Hospice & Palliative Care
      Values, Ethical Principles
         Values
         Ethical Principles
      Conceptual Framework
         Square of Care
         Square of Organization
         Square of Care & Organization
      Norms / Standards of Practice
      Guidelines
      Policies, Procedures
         What are They?
         Developing, Implementing, Evaluating
      Measures
      Definitions of Common Terms
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•  Context
      Tensions
         In Therapeutic Relationships
         Within Host Organizations
         Within Healthcare System, Community
      Who's the Customer
      US Healthcare
         Acute Care Hospitals
         Long-term Care Facilities
         Home
         Hospice Care
      Financing US Healthcare
         Expenditures for EOL Care
         Overview by Settings, Revenue Sources
            Medicare
            Medicaid
            Commercial Insurers
            Managed Care
            Government (VA, Military)
         Financing
            Community Hospitals
            Academic Hospitals
            Subacute, Skilled Care
            Custodial Care
            Ambulatory Care
            Home Care
            Hospice Care
                  Eligibility
                  Covered Services
                  Reimbursement Rates
                  Unintended Consequences
         Financing Physicians
            Coding
               Procedure / Service Codes
                  Coding Based on Time
                     Frequently Used E/M Codes
                        Example
                  Addition of Procedure Codes
            Diagnosis Codes
               ICD-9 Codes for Palliative Care
               Avoiding Concurrent Billing Problems
                  Example
            Documentation
               Example
            Physician Reimbursement
               Medicare
                  Medicare Hospice Benefit
                     Non-hospice Physicians
                     Associated with a Hospice
               Medicaid
               Commercial Insurers
               Managed Care
               Government (VA, Military)
         Financing Non-physician Providers
      Hospital–Hospice Relationships
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•  Program Components
      1º, 2º, 3º Model of Palliative Care Delivery
      Interdisciplinary Care
         Members of Interdisciplinary Team
            Core Competencies
               Physician
               Nurse
               Social Worker
               Chaplain
               Volunteer
      Specialized Environments
      Types of Services
         Consultation Services
            Consultation Etiquette
            Consultation Documentation
               Sample Note
         Inpatient Units
            Developing an Inpatient Unit
               Staffing
               Acuity
               Nursing Model
               Unit Size
                  General Ward vs. Palliative Care Unit
            Roles
            Decisions
            Case Example
               Nursing Staff
               Physician Staff
               Other Staff
               Advice
         Home Care
            Eligibility, Medicare Home Health Benefit
               Covered Services
               Usually Not Covered
         Hospice Care at Home
         Ambulatory Outpatient Care
         Respite Care
      Financing Palliative Care Programs
         Acute Hospital
         Skilled Care Nursing Home
         Hospice
         Home Health
         Ambulatory Outpatient
         Managed Care
      Financing Physicians in Palliative Care
      Financing Non-physicians in Palliative Care
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•  Case Examples
      CAPCManual Case Examples
      Pioneer Program Case Examples
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