The Hospice Proposed Rule includes several important updates that deserve your attention and feedback. Comments are due by June 1st, and submitting them is a simple process. You can visit the Federal Register website, complete the submission form, and send your comments in just a few minutes. Today, I’d like to highlight a few key areas within the proposed rule that you may want to consider addressing in your comments.
One of the more concerning aspects of the proposed rule is the reimbursement update. The proposed increase simply is not enough. CMS is proposing a 2.4% net increase to hospice base rates and the hospice cap, but most providers would agree that operating costs have risen far beyond 2.4% over the past year. Expenses related to staffing, supplies, transportation, and overall operations continue to climb, making it difficult for hospices to keep pace under the proposed reimbursement increase.
In addition, CMS is proposing a significant change to the hospice election statement addendum process. Currently, the addendum is only required when a patient requests it. Under the proposed rule, however, hospices would be required to provide the addendum to every patient at admission.
If finalized, providers would need to ensure the addendum is issued in 100% of admissions, track whether it was signed, and maintain clear documentation whenever a signature is not obtained. Because this is considered a Condition of Payment, any missing documentation or failure to meet the requirement could create substantial risk during medical review. Making this a universal requirement would also mean that every chart selected for review could be evaluated for compliance with this standard.
Another area generating significant concern is the newly released SSVI data. As discussed in the Monday Minute a few weeks ago, this data includes two major components: measures tied to non-hospice spending and calculations based on eight utilization-related elements. Together, these categories can total up to 16 points. In this case, lower scores are better, meaning providers should aim to be as close to zero points as possible.
CMS has also released a public SSVI spreadsheet that remains available for review. The spreadsheet includes hospice providers across the country and shows each organization’s current point calculation, allowing agencies to see where they stand under the proposed methodology.
During the comment period, providers should strongly consider sharing their concerns about the elements included in the SSVI methodology and offering feedback on how this data should, or should not, be used moving forward. At this point, CMS has not clearly defined how it intends to apply the SSVI data, which makes it especially important for hospices to provide input before any future enforcement or oversight measures are established.
We believe this data will ultimately be tied to varying levels of review activity based on a provider’s point score. While CMS has not yet clearly explained exactly how the information will be used or what specific actions may result from higher scores, it is critical that providers submit comments during this period.
Industry feedback will certainly come from state associations and national organizations, but individual provider comments carry tremendous weight. CMS needs to hear directly from hospice organizations about how these proposed changes could affect daily operations, regulatory burden, and most importantly, patient care. Providers should clearly communicate how these proposals may impact access to hospice services and the ability to continue delivering high-quality care to patients and families in their communities.
If you have any questions about the Hospice Proposed Rule, please don’t hesitate to reach out, HPS always stands ready to assist. Please feel free to reach out to us.
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