The industry has been abuzz with the announcement that CMS will proceed with the Special Focus Program as scheduled despite much speculation that the methodology for selection of programs to participate is flawed. If you aren’t aware of this program, you will want to educate yourself on the basic premises and selection metrics. If you have had any challenges in your hospice organization related to quality of care and survey, you may want to prepare for this impending project. This article is a brief overview of what the SFP means to the hospice industry.
What is the Special Focus Program?
The SFP (as it is known) is the latest CMS tool designed to combat poorly performing hospice programs. Operating concurrently alongside multiple claims reviews and special audits (TPE, ADR, SMRC, UPIC, RAC, etc.), SFP focuses less on clinical record reviews and more on reported quality scores and survey outcomes. The fifty hospices who are selected for this intense regulatory scrutiny will be selected in November of 2024 and the program is scheduled to begin in January of 2025.
Who Will Be Selected?
To keep this explanation simple, Medicare will be choosing participants based on calculations defined in an algorithm. The score is based on three major sources of data from the past three years:
- (HCI) Hospice Care Index
- Four measures from the (CAHPS) Consumer Assessment of Healthcare Providers & Systems survey
- Conditional Level Deficiencies (CLDs) and Substantiated Complaints on survey over the previous three years.
Those hospices scoring in the bottom ten percent of all active hospices (counter-intuitively those with the highest scores) will be publicly reported in the SFP 10 Percent List which will be published. Fifty (50) of these “poorest performers” will be selected for the SFP program and will be announced in November 2025. Hospices participating in the program will have a public status of “In Progress”, “Completed”, or “Terminated from the Medicare Program” at least annually on the CMS SFP website – (https://www.cms.gov/medicare/health-safety-standards/certification-compliance/hospice-special-focus-program).
What Does it Mean to Be Selected?
This is a serious process and hospices that are selected will need to pivot resources, time and energy into graduating from this program. Participating hospices will be under intense scrutiny from a survey perspective. Programs will no longer be considered to have deemed status with any accrediting organization (CHAP, ACHC, The Joint Commission), meaning you will be surveyed by the CMS or state surveyors. SFP hospices will undergo full survey at least every 6 months with follow-up surveys and new and existing complaint surveys.
Any conditional survey finding or substantiated compliant or immediate jeopardy could potentially result in being placed on termination track or other enhanced enforcement.
What are the Consequences if a Hospice Fails SFP?
Any hospice that does not comply with all the requirements within the defined timeframe will be under consideration for termination from the Medicare Program. Providers would be considered for termination if they fail any one of the SFP surveys, (whether a 6-month, resurvey of complaint survey) or if they have or receive condition level deficiencies while in the program.
What Should We Do If We Are Selected?
While HCI and CAHPS are considered in the initial calculation, performance on surveys is the road to freedom. If you find yourself on the SFP ten percent list, or if you are chosen as one of the very “Unfortunate 50”, you need to start fixing problems immediately. There is no wiggle room and no time to wait for some magical solution.
First, we recommend that you hire the right consultant team to support your program. IF you could do this without expert help, you would probably not be in this place (sorry, but that is just the reality of this). Review your results and scores, review your data and review all of your processes. Work with your consultant team to define a plan of correction for outlying areas. Contract someone to complete a mock survey that will identify ALL your risks. Engage experts who will roll up their sleeves and help get the necessary work done to correct your problems while empowering your team to continue implementing changes over time. Even if you are not selected, if you fall into the bottom ten percent, there are critical changes that you will want to make to ensure the future success of your hospice.
Hospice Support Specialists is a team of hospice experts who are equipped and prepared to help your program implement essential processes to ensure you can succeed. Connect with us today to schedule a complementary exploration call.
