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Volume 26.15

The Service and Spending Variation Index (“SSVI”), recently introduced by the U.S. Centers for Medicare & Medicaid Services (“CMS”), will present a challenge for the compliance capabilities of hospice providers.

The SSVI was developed in response to non-hospice spending in recent years. The SSVI uses metrics developed from claims to potentially identify inappropriate utilization as well as quality of care or compliance concerns.  The SSVI uses a scoring system; The higher the score the higher the risk of inappropriate hospice utilization and non-hospice spending.

The SSVI will be presented and discussed at the upcoming 2026 Hospice Financial & Compliance Management Conference in Las Vegas on October 1-2, 2026.  Hospices should be, among other things:

  • Monitoring non-hospice spending and live discharge patterns.
  • Ensuring that skilled nursing and aide services align with billed minutes.
  • Tracking length-of-stay, lifetime length-of-stay and facility use to avoid point penalties.
  • Use the SSVI score as a compliance benchmark.

Additional information is available here.

2026 HOSPICE FINANCIAL AND COMPLIANCE MANAGEMENT CONFERENCE NEAR SELL-OUT 

The 2026 “Hospice Financial & Compliance Management Conference” is now available for registration.  Early registration was overwhelming, and the program is close to selling out due to limits on attendance.  The two-day program is being held at the Paris Las Vegas on October 1-2, 2026.

As always, this annual program offers the most extensive hospice financial coverage available. The integration of finance and compliance is critical for the survival and success of any hospice. This year, compliance and the associated financial risks are critical. The conference program, including registration information, is available here.  Discounted room rates are available here or by calling (877) 603-4389.  Make certain to inform Paris Las Vegas that you are attending The Health Group program.  If you are registered but have not secured your room, you are encouraged to do so at your earliest opportunity.  Special room rates are only available through August 31, 2026, and there are many special events occurring in Las Vegas at the same time as our program.  We hope to see you in Las Vegas.

THE 2026 CAP YEAR IS ENDING – WHAT IS YOUR POTENTIAL TO HAVE A CAP LIABILITY? 

The 2026 CAP Year ends September 30, 2026.  All hospices should be looking at the current CAP margin at the end of August 2026, which will represent claims processed for services through July 31, 2026.  Generally, if margins are not more than 25%, the hospice has a possibility of incurring a CAP liability for the 2026 CAP Year.

The margin represents the calculated CAP and the beneficiary counts multiplied by the 2026 CAP amount as set by CMS compared to gross Medicare payments received. Beneficiary counts and Medicare payments are secured through the PS&R System.

Generally, once September claims are processed, we recommend that hospices with margins of less than 25% investigate the potential of eventually incurring a CAP liability.  If a CAP liability appears to be probable, the hospice may want to prepare or have prepared an estimate of the extent of the liability.

Individual hospices may have characteristics allowing margins at the end of the CAP Year to be less than 25% without incurring an eventual CAP liability.  Hospices should communicate with the consultant or employee that is involved in tracking CAP for them if there is any possibility of incurring a CAP liability.  Over 20% of hospices across the country will incur a CAP liability for the 2026 CAP Year.