A new piece of federal legislation is generating significant concern across the hospice industry. The Medicare Advantage Reform Act (H.R. 3467), introduced by Rep. David Schweikert (R-Ariz.), proposes major changes to the Medicare Advantage (MA) program including a requirement that MA plans cover hospice care directly. Currently, when a Medicare Advantage enrollee elects the hospice…
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Who Can Perform a Face-to-Face Encounter?
Who can perform the Face-to-Face (F2F) encounter for home health? This seems like a question that would be easy to answer but has proven to be otherwise. The optimal situation would be when the provider that certifies the patient for home health care would also be the provider that performs the F2F encounter, but we…
Measuring What Matters: MedPAC’s 2025 Hospice Report Calls for Stronger Quality Metrics
In its March 2025 report to Congress, the Medicare Payment Advisory Commission (MedPAC) provided a detailed look at the state of hospice care, highlighting both the stability and ongoing challenges in the sector. Regarding hospice quality care, the report underscored that while quality of care remains difficult to measure comprehensively, existing indicators such as the…
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…
