Exhibit B- Burden Calculation from 2013

Exhibit B – Burden Calculation from 2013 Hospice Rule PRA Package

Hospice Quality Reporting Program Burden Calculations

Background Facts

• Total Number of HOSPICES in U.S. = 3632

• Average Number of Hospice Quality Reporting Program submissions/per Hospice/Year = 2

  • 1 submission for structural measure data - (submission deadline January 31st 1^st)

  • 1 submission for NQF#0209 pain measure – submission deadline April 1^st)

• Number of Hospice Quality Reporting Program submissions for all Hospices/Year = 7,264 submissions per year (3632 Hospices in U.S. x 2 submissions per year = 7,264)

• Average time spent by each Hospice for Structural Measure data submission = 2.5 hours/yr

150 minutes/year (See Exhibit A)

• Average time spent by each Hospice for NQF #0209 Pain Measure Submission = 178.5 hours/year 10,710 minutes/year (See Exhibit B)

CALCULATION OF ESTIMATED ANNUAL HOUR BURDEN:

STRUCTURAL MEASURE

• 150 minutes per each Hospice per year for submission of Structural Measure data x 3632 Hospices in U.S. = 544,800 minutes per ALL Hospice/year for Structural Measure data submission

• 544,800 minutes per ALL Hospices per year for Structural Measure divided by 60 minutes/hour = 9080 hours for ALL Hospices per year for each Structural Measure data submission.

NQF #0209 PAIN MEASURE

• 10,710 minutes per each Hospice per year for submission of NQF# 0209 Measure data x 3632 Hospices in U.S. = 38,898,720 minutes per ALL Hospice/year for NQF #0209 Measure data submission

• 38,898,720 minutes per ALL Hospices per year for submission of NQF# 0209 Measure data divided by 60 minutes/hour = 648,312 hours for ALL Hospices per year for each NQF #0209 Pain Measure data submission.

BOTH MEASURES:

9080 hours for ALL Hospices per year for each Structural Measure data submission.

648,312 hours for ALL Hospices per year for each NQF #0209 Pain Measure data submission.

657,392 hours for ALL Hospices per year for submission of ALL Quality Measure data

Hospice Quality Reporting Program Burden Calculations

Page Two

Cost/Wage Calculation:

Estimate of the average time spent by each Hospice provider per year for submission of Hospice Quality Reporting Program data = 181 hours. The cost burden for the submission of quality data is itemized as followed (further itemization is provided in Exhibits a & B)

Job Description	Measure	Time Spent per year	Average Hourly Rate of Pay	Cost/Wage Calculation
Administrative Assistant	NQF#0209	178.5 hours (10,710 min)	$16.66	$2,973.81
	QAPI measure	70 min	$16.66	$ 19.43
Registered Nurse	QAPI measure	80 min	$33.23	$ 44.30
TOTAL		181 hours (10,860 min)		$3,037.54 Per year

$3,038*- Total Annualized Cost To Each Hospice Providers

$11,034,016* - Total Annualized Cost To ALL Hospice Providers

$3,038* per Hospice per year x 3632 Hospices in the U.S. = $11,034,016*

Estimated Average Annual Cost / Provider = $3,038*

($11,034,016*/ 3632 Hospices)

Estimated Average Yearly Cost per submission of all QRP data for each Hospice = $1,519*

($11,034,016*/ 7,264 submissions)

Estimated Actual Yearly Cost per Hospice for Submission of Structural Measure Data: $63.73*

Estimated Actual Yearly Cost per Hospice for Submission of NQF #0209 Measure Data: $2,973.81*

*NOTE: For purposes of total annualized cost calculations, all numerical figures have been rounded up or down to the nearest whole number.

Exhibit A

Time Estimates for Reporting of the Structural / QAPI Measure

By Each Individual Hospice Provider

Activity	Time	Frequency of Activity	Job description of person(s) who perform this task	Average Hourly Wage
Download and read User Guide	60 minutes	One time only *	Administrative Assistant	$16.66 x 60 min./yr. =$16.66 per year
Refer to users guide while entering data for submission	20 minutes	Once yearly per submission	Registered Nurse (R.N.)	$33.23 x 20 min./yr. =$11.07 per year
Create web account/login on CMS website	10 minutes	One time only*	Administrative Assistant	$16.66 x 10 min./yr. =$2.78 per year
Gather/review QAPI program documentation of indicators used in Q4 2012, map to dropdown structure in the User Guide	30 minutes	Once yearly per submission	Registered Nurse (R.N.)	$33.23 x 30 min./yr. =$16.61 per year
Login and enter data for structural measures using dropdowns	30 minutes	Once yearly per submission	Registered Nurse (R.N.)	$33.23 x 30 min./yr. =$16.61 per year
Total	70 minutes 80 minutes 150 minutes (2.5 hours)		80 minutes spent by R.N. @ hourly wage of $33.23 70 minutes spent by Administrative Assistant @hourly wage of $16.66	$16.66 $11.07 $ 2.78 $16.61 $16.61 $63.73

Exhibit B

Time Estimates for Reporting of the NQF #0209 Pain Measure

By Each Individual Hospice Provider

Activity	Time	Frequency of Activity	Job description of person(s) who perform this task	Average Hourly Wage
Refresher reading of User Guide*	30 minutes per Reporting Period 0.5 hours per year	One time only *	Administrative Assistant	$16.66 x 30 min./yr. =$8.33 per year
Aggregate the clinical data for collection of the required data elements for NQF 0209	14 hours per month; or 42 hours per quarter; or 168 hours per year (10,080 minutes/yr)	Once yearly per submission (or may be done on a quarterly basis)	Administrative Assistant	$16.66 x 14 hours/mo. = $233.23 $16.66 x 168 hrs/yr. = $2,798.88 per year
Login and enter the 7 data elements	0.83 hours per month; or 2.5 hours per quarter; or 10 hours per year (600 minutes/yr)	Once yearly per submission (or may be done on a quarterly basis)	Administrative Assistant	$16.66 x 10 hours/yr. = $166.60
Total	30 minutes @ $16.66/hr 10,080 minutes @$16.66/hr 600 minutes @$16.66/hr 10,710 minutes (178.5 hours)			$8.33 $2,798.88 $166.60 $2,973.81