The Death Knell for Debility and Adult Failure to Thrive as Terminal Diagnoses in Hospice
May 24, 2013 Terri Maxwell

On May 10, 2013, the Centers for Medicare & Medicaid Services (CMS) issued a Proposed Rule entitled FY 2014 Hospice Wage Index and Payment Rate Update; Hospice Quality Reporting Requirements; and Updates on Payment Reform [CMS-1449-P]. This rule contains important information, including proposed hospice rates for 2014 (no good news here, rates are going down), changes to the hospice quality reporting program, alterations to the cost report, and an update to hospice payment reform options.
In addition to these proposed changes, CMS “clarified” a number of coding requirements that has had the industry buzzing. Included in these clarifications is a directive to hospices that non-specific diagnoses such as Debility or Adult Failure to Thrive (AFTT) may no longer be listed as a principle terminal diagnosis on the hospice claim. Claims submitted with these diagnoses would be returned to the provider (RTPd) for a more definitive hospice diagnosis. However, Debility and AFTT can and should be listed on the claim as secondary (related) conditions to support prognosis if indicated. CMS states that disallowing these diagnoses is not a new position, which comes as a surprise to most of us in the industry (otherwise why does CMS’ Medicare Administrative Contractor (MAC), Palmetto GBA, have an LCD guideline for AFTT?).
Why is CMS making this clarification now?
According to the Proposed Rule, CMS is taking action because of the growing number of patients admitted to hospice with these ill-defined conditions that are inherently symptom syndromes, not actual terminal diagnoses. This is born out by National Hospice and Palliative Care Organization (NHPCO) statistics, listing Debility Unspecified as the leading non-cancer diagnosis in hospice, comprising