Volume 25.10
Abt Global, working on behalf of the Centers for Medicare & Medicaid Services (“CMS”), hosted a panel of technical experts to discuss hospice wage index reform.
Hospices have expressed concerns regarding the use of the hospital wage index for purposes of wage adjusting hospice payments. There are many factors that cause the hospital wage index to not be representative of hospice services including, but not limited to:
- Staffing rates,
- Occupational mix,
- Service distribution,
- Measurement data, and
- Hospital wage index adjustments, not applicable to hospices.
Several individuals representing the National Alliance for Care at Home (“Alliance”) participated in the meeting and were involved in the discussions regarding the potential change.
Following the meeting, the Alliance issued a letter to CMS regarding the establishment of a hospice specific wage index and the approach presented to the group regarding how such a wage index would be developed. The letter is available here.
We encourage the development of a hospice specific wage index; however, we agree with the comments developed by the Alliance regarding this process.
TELEHEALTH USE FOR HOSPICE AND HOME HEALTH – OCTOBER 1, 2025
The federal government was shut down effective October 1, 2025, and telehealth flexibilities provided to hospices and home health providers has expired, including those applicable to the face-to-face (“F2F”) encounter.
Hospices and home health agencies must ensure that all F2F encounters on and after October 1, 2025, are in-person encounters to comply with Medicare coverage requirements.
It is possible that Congress will eventually extend the telehealth flexibilities retroactively to October 1, 2025, however, there are specific timing requirements for the encounter in both home health and hospice. Providers must observe the requirements that are in place at the time the encounter is conducted.
CAP YEAR ENDED SEPTEMBER 30, 2025
The 2025 CAP Year ended September 30, 2025. Hospices should make certain they have access to the PS&R System to ensure the self-determined filing can be made on or after January 1, 2026, but before February 28, 2026. Additionally, hospices should prepare for any CAP liabilities that will need to be submitted early in 2026.
AGENDA FINALIZED FOR 2025 HOSPICE FINANCIAL ADMINISTRATION CONFERENCE
The final agenda for the 2025 Hospice Financial Administration Conference, October 16-17, 2025, has been set and includes the following:
- The Current State and Future Direction of the Hospice Industry;
- Identification of Payment and Integrity Changes;
- Preparing or Assisting the Cost Report;
- HOPE Tool; Submission Compliance, Impact and Public Reporting;
- Conditions of Participation vs. Conditions of Payments;
- Hospice Audits and Documentation;
- Optimizing Revenue Cycle;
- Everything CAP;
- Enhancing Accounting and Financial Records;
- Continued Expansion of Enrollment Reporting.
Program information, hotel information, and registration information is available here. We look forward to seeing you in Orlando.