Volume 26.12
The Proposed 2027 Home Health Rule, found here, published July 6, 2026, provides clarification that Medicare-certified home health agencies can provide certain billing codes to offer community-based palliative care to qualifying patients. Of course, these services are only available to those Medicare beneficiaries that have not elected the hospice benefit.
The early response to this clarification provided in the Proposed Rule is generally favorable, as reimbursement for palliative care services provided outside of the hospice benefit is currently generally insufficient to cover the costs of these services. It is important to recognize that the Proposed Rule is not really a new policy; however, CMS has indicated that additional regulatory guidance is forthcoming.
The specific implications, as discussed in the Proposed Rule, appear to present several issues related to the implementation. Some of these are as follows:
- The Proposed Rule does not really provide for a new community-based palliative care benefit. To be eligible for home health coverage, the patient must meet eligibility requirements including being homebound. This would, by itself, exclude many patients from the benefits such services would provide.
- Community-based palliative care would not be a covered service unless such services are provided by a Medicare-certified home health agency. Hospices would not be able to provide these services and be reimbursed unless they also operate a Medicare-certified home health agency.
- Home health services are generally evaluated based on improvement of underlying conditions and the patient’s progress to recovery.
- Hospice services include a broader array of services which may benefit palliative, or certain palliative care patients, beyond what a home health agency may provide.
Hospice providers are currently prohibited from seeking Medicare-certified home health agency certification because of the recently imposed moratoria. Hopefully, comments will be submitted on the Proposed Rule that provide for a more comprehensive review by CMS regarding this benefit, which have significant value to both providers and patients.
LAS VEGAS FINANCIAL AND COMPLIANCE PROGRAM WILL SELL-OUT
The 2026 “Hospice Financial & Compliance Management Conference” is now available for registration. Early registration has been overwhelming, and the program is expected to sell out. Program space is limited to enhance the quality and networking opportunities for the attendees. 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. There are many special events occurring in Las Vegas at the same time as our program. See you in Las Vegas.