Hospice & Home Health News 2025Dec04

LeadingAge and Hospice Groups Ask CMS to Waive HOPE Timeliness Requirement

In a November 24, 2025, letter to the Centers for Medicare and Medicaid Services (CMS) Administrator Oz, LeadingAge along with the national Alliance for Care at Home and the National Partnership for Healthcare and Hospice Innovation request CMS waive the Hospice Outcomes and Patient Evaluation (HOPE) timeliness submission requirement for the first quarter post-implementation. The letter argues that simultaneous launch of the HOPE tool and migration to iQIES coincided with the first day of the government shutdown which led to reduced Help Desk responses to fatal errors and rejections, configuration issues beyond providers' control, and absence of real-time problem resolution. The consequence of adverse outcomes cannot be understated. The failure to comply with requirements of the Hospice Quality Reporting Program to submit 90% of patient records carries a 4% annual payment update reduction risk. Negative financial consequences for hospice providers is largely dependent this quarter not only on the success of two transitions—iQIES and HOPE—that are not within their control but also during a uniquely challenging government shutdown. LeadingAge has repeatedly advocated for waiving the 90% reporting threshold during the transition to HOPE. The impact of the government shutdown only exasperates hospices' compliance risks.

Senators Urge Leadership to Reject MA Hospice Carve-In

On November 20, Senators Roger Marshall, MD, (R-KS) and Sheldon Whitehouse (D-RI) sent a letter to congressional leaders urging them to reject any proposals that would roll the Medicare hospice benefit into the Medicare Advantage (MA) program. The senators argue that integrating hospice into the current MA program would jeopardize access by layering additional managed care terms (or policies) on top of an already managed and coordinated benefit. They also cite the failed Value Based Insurance Design (VBID) model which identified clear challenges for both hospices and MA plans with administrative burdens, difficulty creating networks, and delayed payments for hospice claims. The demonstration also did not result in increased or earlier access to hospice or better care for patients.

CMS Adds Hospice Billing Rejection Edit to Hospital In-Patient and Out-Patient Services

In a November 20 Change Request (CR 14219) the Centers for Medicare and Medicaid Services instructed Part A/B Medicare Administrative Contractors (MACs) to implement new system edits which will automatically compare the primary diagnosis codes on hospital inpatient and outpatient claims with the hospice claim's primary diagnosis codes. The edit will deny hospital inpatient and outpatient claims when there is a hospice claim for the same Medicare beneficiary within the same covered period with condition code 07 with same primary diagnosis. This edit is in response to concerns first raised in a 2024 Office of Inspector General (OIG) report on outpatient services provided to hospice enrollees. The report identified improper payments for services provided to hospice enrollees related to their terminal illness which were already covered under the hospice benefit. In these instances, the services should have been provided directly by the hospices or under arrangement with the hospice and the hospital. The edit will be effective April 1, 2026 and CMS plans to issue additional education for providers to comply with billing expectations.

CY2026 Final Home Health Rule Released; Includes Major Reduction in Proposed Payment Cut

On November 28, CMS released the Calendar Year (CY) 2026 Home Health Prospective Payment System Final Rule. The CY 2026 updated rates include the final CY2026 HH payment update of an estimated 2.4% increase ($405 million increase), which is offset by an estimated 0.9% decrease that reflects the final permanent adjustment ($150 million decrease), an estimated 2.7% decrease that reflects the final temporary adjustment ($460 million decrease), and an estimated 0.1% decrease that reflects the updated fixed-dollar loss (FDL) ratio for outlier payments ($15 million decrease). CMS estimates that Medicare payments to home health agencies (HHAs) in CY2026 will decrease in the aggregate by an estimated 1.3%, or $220 million, compared to CY2025, based on the finalized policies.

The final rule reduces funding when providers can ill afford any cuts. However, this final rule is a large improvement over the proposed rule. To compare: in the proposed rule, CMS estimated that Medicare payments to HHAs in CY2026 would decrease, in the aggregate, by an estimated 6.4% or $1.135 billion dollars compared to CY2025. In the final rule, CMS estimates that Medicare payments to HHAs in CY2026 would decrease, in the aggregate, by an estimated 1.3% or $220 million compared to CY2025.

This is a net positive change of $915 million between the proposed rule and the final rule. Any cut is challenging and unacceptable in this moment of intense financial pressure. However, this represents an 80% reduction in what CMS proposed to cut – an advocacy win. There is still work to do to ensure long term sustainability of nonprofit and mission-driven HHAs so there is access to high quality care at home for the older adults they serve. 

Please join the home health network at 2pm on Tuesday, December 3 for more details on the rule.

Other resources on the rule are:

·       The press release for the rule can be found here.

·       The final rule text can be found here.

·       Our comments on the proposed rule can be found here.

·       LeadingAge's press statement on the final rule is here. 

·       LeadingAge's initial article is here

Here is your weekly Home Health Weekly Recap from National.

Here is your weekly Hospice Weekly Recap from National.