November 5, 2024
Termination of the Hospice Benefit Component of the Value-Based Insurance Design (VBID) Model on December 31, 2024
The Centers for Medicare & Medicaid Services (CMS) has decided to conclude the Hospice Benefit Component of the Value-Based Insurance Design (VBID) Model as of December 31, 2024, 11:59 PM. Medicare Advantage Organizations (MAOs) participating in the Hospice Benefit Component must continue to cover all hospice elections for beneficiaries in participating Plan Benefit Packages (PBPs) for care delivered through December 31, 2024. Starting with services provided on or after January 1, 2025, financial responsibility for hospice coverage for MA enrollees that were covered through the Hospice Benefit Component will revert to Original Medicare (that is, the Medicare FFS program).
For hospice elections that extend beyond the termination date of the Hospice Benefit Component, hospice providers should not discharge any patient solely because of their coverage in a plan participating in the Hospice Benefit Component prior to CY 2025. For those hospice elections that continue into 2025, no new Notices of Elections (NOEs) will be required.
During the model years, hospices were required to submit NOEs and all hospice claims to their Medicare Administrative Contractor (MAC) for informational purposes, monitoring and evaluation during the model. By following these submission requirements, a seamless billing transition after the conclusion of the model would occur when Original Medicare assumes financial responsibility. Therefore, the sequential claims submitted for services provided on or after January 1, 2025, Original Medicare will become financial responsibility. If a hospice did not follow the informational billing requirements during the model, claims for dates of service of January 1, 2025, and later that correspond with a late NOE (received January 6, 2025, or later) may be subject to late NOE penalties unless it was beyond the hospice’s control to submit a timely NOE.
- For example, a patient elected hospice on September 6, 2024, while enrolled in a participating 2024 VBID plan and they continue their election beyond the conclusion of VBID on December 31, 2024. The hospice should have submitted a timely NOE to their MAC for the election date. In this scenario, if the hospice initially submits an NOE for the September 6, 2024, hospice election to their MAC on January 16, 2025, a claim with dates of service January 1, through January 15, 2025, would be subject to late NOE penalties.
More details are available in the Operations and Claims section of the Calendar Year (CY) 2024 Technical and Operational Guidance, linked below.