CMS Unveils FY 2026 Hospice Proposed Rule: What Providers Need to Know

On April 11, 2025, the Centers for Medicare & Medicaid Services (CMS) issued the proposed rule for the Fiscal Year (FY) 2026 Hospice Wage Index and Payment Rate Update (CMS-1835-P), detailing planned changes to Medicare hospice payment rates, regulatory guidance, and updates to the Hospice Quality Reporting Program (HQRP).  These proposed changes are part of…

These Errors Keep Showing Up in Audits—Let’s Break the Cycle

Our audit reviews continue to reveal the same key issues: eligibility, certification, and documentation. Medicare home health coverage isn’t just about providing care—it’s about clearly demonstrating the medical necessity through accurate and timely records. Home Health Eligibility: All Criteria Must Be MetTo qualify for Medicare home health services, the patient must: Plan of Care (POC)…

Ensuring Compliance with General Inpatient (GIP) Care

Hospice providers continue to be under high scrutiny for their use of General Inpatient (GIP) care.  As audits increase, strict compliance is essential to avoid financial penalties and ensure quality patient care. The Heightened Regulatory Landscape A 2016 Office of Inspector General (OIG) study found that 31% of GIP claims were billed inappropriately, leading to…

Coding Updates

The CDC’s National Center for Health Statistics announced that it will not hold a Spring Coordination and Maintenance (C&M) Committee Meeting for 2025. This meeting is normally held twice a year in the spring and the fall to discuss ICD-10 coding proposals.  The CDC website, states, however that this change will not affect the ICD-10-CM…

Hospice Outcome & Patient Evaluation Tool

Hospices will begin completing the Hospice Outcome & Patient Evaluation (HOPE) on October 1, 2025.  The final HOPE item sets and HOPE guidance manual were released on September 16, 2024.  The HOPE data collection tool replaces the Hospice Item Set (HIS) but includes many of the same items.  Medicare-certified hospices will complete HOPE records for…

Revised Medicare Non-Coverage Notices: What Providers Need to Know in 2025

As of January 1, 2025, updated versions of the Notice of Medicare Non-Coverage (NOMNC, CMS-10123) and Detailed Explanation of Non-Coverage (DENC, CMS-10124) are in effect.  These changes, approved by the Office of Management and Budget (OMB), bring new requirements and enhanced clarity for providers and beneficiaries.  Medicare Advantage (MA) plans have an extended deadline for…

What is ‘All-Payer OASIS Data Collection and Submission’?

CMS has lifted the long-standing suspension of OASIS requirements for collection of data on non-Medicare/non-Medicaid patients. This means that Medicare-certified home health agencies will be required to collect and submit OASIS data on all patients, regardless of payer. The new guidance is included  in the OASIS-E1 guidance manual and CMS has also released a Q&A…

MedPAC Draft Recommendations for a 7% cut on Home Health Medicare Payments in 2026

During its December meeting, the Medicare Payment Advisory Commission (MedPAC) issued draft recommendations advising Congress to reduce Medicare payments to home health agencies by 7% starting in 2026. The recommendations are part of MedPAC’s annual evaluation of payment adequacy across provider settings, which includes assessments of beneficiaries’ access to care, quality, capital availability, and cost-payment…

CMS Reinforces Hospice Oversight: Focus on Program Integrity and Fraud Prevention

The Centers for Medicare and Medicaid Services (CMS) on November 13, 2024, posted the memo Ref: QSO-25-06-Hospice (Subject: Ensuring Consistency in the Hospice Survey Process to Identify Quality of Care Concerns and Potential Fraud Referrals) which outlines updated guidance to ensure consistency in the hospice survey process.  It emphasizes identifying and addressing quality of care…

Comorbidity Adjustments

On November 4th, CMS posted an updated Grouper Tool in order to capture the changes that will be effective on January 1st, 2025, regarding low and high comorbidity adjustments.  For fiscal year 2025, there are 22 Low comorbidity adjustments (same number as 2024) and 97 High comorbidity adjustments (down from the 102 in 2024).  Low…