Bluegrass Care Navigators Issues Public Comment on Centers for Medicare & Medicaid Services Proposed Rule

WASHINGTON, June 17 -- Liz Fowler, president and CEO of Bluegrass Care Navigators, Lexington, Kentucky, has issued a public comment on the Centers for Medicare and Medicaid Services' proposed rule entitled "Medicare Program; FY 2021 Hospice Wage Index and Payment Rate Update". The comment was written on June 6, 2020, and posted on June 10, 2020:

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Hospice of the Bluegrass, Inc., doing business as Bluegrass Care Navigators (BCN), with headquarters in Lexington, Kentucky appreciates the opportunity to comment on CMS proposed rule CMS-1733-P. BCN provides hospice care in 32 counties across central, northern, and eastern Kentucky and is committed to providing the highest quality hospice care to terminally ill patients and their families, to exploring innovative approaches that improve health care delivery, and to being a good steward of the Medicare and Medicaid dollar.

BCN is supportive of the major provisions in the proposed rule but we continue to have reservations about the modifications to the hospice election statement and election statement addendum. Consequently, we respectfully request further delay to modifications to the hospice election statement and election statement addendum.

For a full description on the reasons for our reservations, please see the comments from the National Hospice and Palliative Care Organization on these issues. Put succinctly, we worry that the proposed changes can confuse patients and families about insurance coverage and potentially delay access to hospice services during a time when patients and families are already delaying care due to the COVID-19 pandemic.

Additionally, our organization is strained administratively due to the COVID-19 pandemic. Implementing the new processes required by changes to the election statement and addendum would present a significant administrative burden.

Conclusion

BCN appreciates the commitment of HHS and CMS leadership to improving access to high-quality hospice care and the thoughtfulness of this proposed rule. We welcome the opportunity to discuss any of these issues or our comments in more detail and contribute to solutions oriented conversations.

Please do not hesitate to contact me with any questions

Sincerely,

Liz Fowler

President and CEO

Bluegrass Care Navigators

[email protected]

859.296.6810

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The proposed rule can be viewed at: https://www.regulations.gov/document?D=CMS-2020-0037-0002

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