Hi, everyone.
As anticipated, CMS has released materials for the CY2025 year of the MA VBID model, including a Request for Applications (RFA) and a Request for Information (RFI) related to the MA VBID Hospice Benefit Component. Following is a link to the MA VBID page: https://www.cms.gov/priorities/innovation/innovation-models/vbid
As many of you may recall, in March (when CMS announced its intent to extend the VBID model through CY2030), the agency also indicated plans to change the concurrent care CMS announced it would be making changes to the concurrent care provisions of the MA VBID Hospice Benefit Component (effective for CY2025), as well as to the network adequacy requirements beginning with CY2026. As part of the CY2025 MA VBID Hospice Benefit Component RFA, CMS has removed the word "transitional" from the "transitional concurrent care" component description to covey greater flexibility relative to the length of time a beneficiary may receive these services. Following is an explanation of this change:
"For CY 2025, CMS is more closely aligning flexibilities for concurrent care under the VBID Model with those offered in other CMS Innovation Center models. Namely, the Accountable Care Organization Realizing Equity, Access, and Community Health (ACO REACH) Model and the Kidney Care Choices (KCC) Model include benefit enhancements to allow Model participants to offer concurrent care for beneficiaries who elect the hospice benefit.
"Accordingly, under the VBID Model, "transitional concurrent care" is now referred to as "concurrent care." By describing the VBID Model's flexibility as "concurrent care", CMS would like to clarify that participating MAOs may create programs that do not have any time-based limits on curative services, items, or drugs during a hospice election. For example, participating MAOs are not required to implement a 30-day limit for any services, items, or drugs offered through a concurrent care program. Removing a time-based limit may ultimately better achieve the intended goals and intent of this flexibility.
"However, given the number of factors that may influence whether an enrollee chooses to elect hospice, CMS maintains broad flexibility for participating MAOs to construct their concurrent care programs in collaboration with interested parties such as enrollees, caregivers, family members, providers, and others. In other words, this clarification does not impose any new obligations on participating MAOs."
As referenced above, CMS has also issued an RFI for the VBID Model and the VBID Model Hospice Benefit Component related to advancing health equity and expanding access to higher quality hospice care. The RFI related to quality of hospice care is particularly focused on CMS' plans for changing its network adequacy requirements beginning in CY2026 to allow MA organizations to limit patient choice of hospice providers to only in-network hospices. NAHC will be developing comments to submit in response to the RFI, which must be submitted to the VBID Mailbox (VBID@cms.hhs.gov) by January 31st, 2024. .
Take care,
Theresa
Theresa M. Forster
VP for Hospice Policy & Programs
National Association for Home Care & Hospice
Office: 202-547-7424
Direct: (202) 355-1661
tmf@nahc.org
