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Volume 23.21

CMS waived the requirement for hospices to use volunteers (42 CFR §418.78(e)) during the Public Health Emergency (“PHE”); however, the requirement is again effective January 1, 2024.  Many hospices had difficulty complying with this requirement even before the PHE.

Hospices need to begin addressing this requirement immediately.  Rebuilding the volunteer base post PHE is not going to be an easy task for many hospices.  Hospices may be subjected to a standard level survey citation if they don’t meet the five percent (5%) of hospice patient care hours requirement.  A standard level deficiency means that the hospice is not compliant with one of the standards under a condition of participation.  The hospice remains certified with this type of deficiency but will need to submit a plan of correction to the surveying agency describing how the deficiency will be mitigated.

Hospices must capture Volunteer Coordination costs in the accounting records for inclusion in the Hospice Cost & Data Report.  If a Hospice employee provides volunteer coordination services and other services, the compensation should be segregated in the accounting records or appropriate information should be provided to that individual responsible for cost report preparation, allowing for any necessary reclassification of costs.

Additionally, the Hospice should capture the hours spent by volunteers into the following, at a minimum:

  • Patient support – patient’s residence,
  • General support – patient’s residence (housekeeping, meals, errands, etc.),
  • Patient support – hospital,
  • Patient support – SNF, long-term care,
  • Administrative services support,
  • Fundraising activities, and
  • Bereavement.

A qualified cost report preparer, internal or external, should be able to reasonably allocate Volunteer Services Coordination costs on the Hospice Cost & Data Report based on this information.  Additional categorization of volunteer hours will further enhance the quality of the Hospice Cost & Data Report.


Earlier this year, the Boards of the National Association for Home Care & Hospice (“NAHC”) and the National Hospice and Palliative Care Organization (“NHPCO”) agreed to a joint process to explore the formation of a new organization to combine the strengths of both NAHC and NHPCO and better serve members with a unified voice on behalf of the entire community of hospice, home care, palliative care, serious illness, and other care at home providers.

The NAHC and NHPCO Boards of Directors will work together, in consultation with member volunteers from both organizations, to determine details of how a consolidated organization could represent the best interests of the combined memberships. To facilitate an effective process, both Boards have decided to suspend elections for new Directors this year.

NAHC and NHPCO have scheduled 2024 conferences as follows:

NHPCO 2024 Virtual Interdisciplinary Conference – Focusing on Opportunities and Challenges on the Front Lines; April 15-17, 2024.

NAHC Financial Management Conference and Expo – July 21-23, 2024; Caeasr’s Palace, Las Vegas, NV.

NAHC Home Care and Hospice Conference and Expo – October 20-22, 2024; Tampa, Florida.


We look forward to seeing you at the 2023 Hospice Financial Management and Administration Conference in Fort Lauderdale on November 9-10, 2023.  While the program is essentially full, space will accommodate a couple more attendees for those still wanting to register.  Information is available here.

At the conclusion of the program on Thursday, November 9, 2023, we are offering a short one-hour reception.  Light snacks and beverages will be provided.