Telehealth Flexibility for the Hospice Face-To-Face Recertification Visit

Re: Telehealth Flexibility for the Hospice Face-To-Face Recertification Visit

Dear Congressional Leaders:

Thank you for your leadership and support in expanding access to quality healthcare through telehealth. These flexibilities have helped improve patient care delivery across the United States. As organizations representing the full array of hospice and community-based palliative care providers, professionals, and volunteers, we write to you today in strong support of extending the telehealth flexibility for the face-to-face (F2F) encounter required during recertification of hospice eligibility. This flexibility has yielded benefits for patients and providers, allowing hospice providers to focus on direct patient care, reducing unnecessary burdens, and improving patient and family satisfaction and it is critical that this flexibility be maintained going forward.

Hospice is holistic, interdisciplinary care, meaning beneficiaries receive visits and care from the entire interdisciplinary team consisting of a physician, nurse, hospice aide, social worker, chaplain, volunteer, and bereavement specialist. As of January 1, 2024, this may now also include a marriage and family therapist or mental health counselor. Together with the patient and family, this team constructs an individualized plan of care to meet patient and family needs, which reflect their desired outcomes and goals. Hospice services are delivered around the clock based on the patient’s individualized plan of care.

The F2F requirement is a low-touch, administrative component of the recertification process intended to collect clinical information to determine continued eligibility. This process can be conducted as successfully via telehealth as it can in-person. Recent research concluded there were no “statistically significant differences in reauthorization recommendations found between telehealth and in-person visits.” As it is not a care visit, it cannot be billed separately like other hospice physician visits. Extending this telehealth flexibility does not have an associated cost.

The in-person requirement is burdensome on hospice providers using up valuable physician and nurse practitioner (NP) time commuting to patients’ homes for paperwork visits rather than visiting other patients who need critical and timely care. This is true for providers operating in rural and high-traffic urban areas where the time spent on travel is measured in hours. By allowing this telehealth flexibility, physicians and nurse practitioners can spend more time delivering care and less time traveling between patient locations.

This flexibility is always important; there are circumstances where it is invaluable. One instance our collective members discuss with frequency is for patients starting hospice with a new provider at a time that coincides with the required administrative timing for a face to face. These referrals are often made with imminent need for care; being able to use telehealth to start care in these cases is particularly valuable. Given that research and anecdotes from our members support that this visit is equally effective whether in person or virtual, this example of the importance of expediency should underscore the need for this flexibility to continue for the benefits of patients, families, and hospice providers.

Provisions extending this flexibility have been included in various telehealth proposals including the CONNECT for Health Act (H.R. 4189 / S. 2016), the Telehealth Modernization Act (H.R. 7623 / S. 3967), the Preserving Telehealth, Hospital, and Ambulance Access Act (H.R. 8261) – which was unanimously passed out of the Ways and Means Committee, and the Hospice Recertification Flexibility Act (H.R. 8278), demonstrating broad bicameral and bipartisan support.

Telehealth is an effective means of conducting these administrative visits without increasing Medicare costs. Extending this flexibility, especially in rural and high-traffic urban areas, will significantly benefit both patients and providers. We strongly urge Congress to ensure the Hospice F2F telehealth flexibility is included in any telehealth package before it expires at the end of the year.

Thank you for your attention to this critical issue. We look forward to working with you to support the needs of hospice patients, families, and providers across the country.

Sincerely,
The National Alliance for Care at Home
The National Coalition of Hospice & Palliative Care
Alliance for the Advancement of End of Life Care
American Academy of Hospice and Palliative Medicine
Association of Professional Chaplains
HealthCare Chaplaincy Network
Hospice & Palliative Nurses Association
LeadingAge
National Partnership for Healthcare and Hospice Innovation
Physician Associates in Hospice and Palliative Medicine
Social Work Hospice & Palliative Care Network
Association for Home & Hospice Care of North Carolina
Connecticut Association for Healthcare at Home
Florida Hospice & Palliative Care Association
Georgia Hospice and Palliative Care Organization
Granite State Home Health and Hospice Association (NH)
Healthcare Association of Hawaii
Home Care and Hospice Association of Colorado
Homecare and Hospice Association of Utah
Hospice & Palliative Care Association of Arkansas
Hospice & Palliative Care Association of Iowa
Hospice & Palliative Care Association of New York State
Hospice & Palliative Care Network of Maryland
Hospice and Palliative Care Federation of Massachusetts
Hospice Council of West Virginia
Illinois Hospice and Palliative Care Organization
Indiana Association for Home and Hospice Care
Kōkua Mau, A Movement to Improve Care
Louisiana Mississippi Hospice and Palliative Care Organization
Michigan Home Care & Hospice Association
Nebraska Hospice and Palliative Care Association
Oregon Hospice & Palliative Care Association
South Carolina Home Care & Hospice Association
Tennessee Association for Home Care
Texas New Mexico Hospice & Palliative Care Organization
The Alabama Hospice and Palliative Care Organization
Virginia Association for Home Care and Hospice
Washington State Hospice & Palliative Care Organization
West Virginia Council for Home Care and Hospice