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CHAPcast: Your Trusted Partner on the Go
For over 60 years, CHAP has been leading the way in home and community-based care, and now CHAPcast is leveling up! With a dynamic new format, co-hosts Jennifer Kennedy and Kim Skehan bring their expertise, passion, and a touch of personality to every episode.
Get ready for deeper dives into the issues that matter—breaking down policy updates, exploring cutting-edge trends, and sharing practical tools to help you thrive. Fresh perspectives and actionable insights you can use right away.
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CHAPcast by Community Health Accreditation Partner
The Hospice Final Rule 2026 - What Hospice Providers Need to Know
The FY2026 Hospice Final Rule brings positive changes with a 2.6% payment increase and significant regulatory clarifications that reduce administrative burden for providers nationwide. Jennifer Kennedy and Kim Skehan discuss critical updates affecting hospice operations, with special focus on the imminent HOPE assessment implementation.
• 2.6% national payment increase for hospices with cap amount set at $34,465.34
• Regulatory clarification allowing any physician member of the IDG to complete certification of terminal illness
• Face-to-face attestation requirements simplified, eliminating need for separate documentation
• HOPE implementation confirmed for October 1st with data submission through iQIEs system
• 90% compliance threshold remains in effect with potential 4% payment reduction for non-compliance
• Final date for HIS corrections is February 5, 2026
• CMS holding on decisions regarding interoperability and deregulation requests
Providers should evaluate the financial impact of wage index changes, update policies to align with regulatory modifications, and ensure readiness for HOPE implementation through comprehensive staff training.
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Greetings. I'm Jennifer Kennedy, the Lead for Compliance and Quality at CHAP, and welcome to this session of CHAPcast. In today's session, we're going to talk about the hospice fiscal year 2026 final rule that came out at the beginning of August of 2025. And, of course, I have my good friend and colleague here to do the chatting with me about all things Hospice Final Rule Kim Skian, and she is our Vice President for Accreditation. Hi Kim, how are you doing?
Speaker 2:Hi, jennifer, I'm doing really well. I'm actually excited to talk through the Hospice final rule. I was actually thinking about you when I was reviewing and all of your years of it's not perusing deep, diving with all of the federal registers, all the proposed rules and final rules, and from your perspective, you know where do you see this, this final rule? It appears as though it's a little more comprehensive, if you will, and easier than or less onerous. I guess I would say yeah, that's it. That's the word Less onerous.
Speaker 1:That's exactly it. So when the proposed rule came out earlier this year, I, you know I always sweat to like, oh God, what's going to be in it and how many pages is it going to be? And 82 pages, that's nothing, right. And I think you're right. I think it was completely less onerous than years past and I think the, you know, the first thing that we could start out with is, in addition to providing an overview of, you know, the various provisions in the rule. But, kim, if you want to get us started about, you know some good news, it's the payment update.
Speaker 2:Yes, absolutely, and yep, I'm sorry, just as an update. Really, the best news, if you will, from this with the payment update is that there is an overall 2.6% increase nationally and the aggregate cap is $34,465.34. It also is important to note that your actual payment update or payment change will be based on your own MSA, your own I'm sorry CBSA, to be able to make sure that you know that there may be an adjustment up or down. But overall, I would say that hospice at the moment and I'm really going to knock on wood when I say this, you know is faring overall much more positively in terms of at least having the opportunity to have a rate increase. Continue to have a rate increase, given the environment.
Speaker 1:Yeah, I agree. You know it is a fact that we can look at that March MedPAC report that comes out every year for Congress and you know, look at that and it's usually the timing is about a couple of weeks before the proposed hospice rule posts. But to get an idea of what could be coming in terms of payment idea of what could be coming in terms of payment either update or staying the same or what have you. But I'm very happy for hospice providers out there that it is a 2.6 bump in their rate. We did have a couple of regulatory text updates too, so let's talk about those, kim.
Speaker 2:Sure.
Speaker 2:Well, I think it's important to note that the regulatory updates that are published in the final rule are not substantive in terms of a regulatory language change and will not change the intent of the regulation itself, just really further clarifies and really supports increasing overall or decreasing burden, I guess I would say, for hospices.
Speaker 2:So the first is the CMS finalizing the proposal to add the text or the physician member of the hospice interdisciplinary group to changes that would include both to the conditions of payment, the Medicare benefit policy manual, and also we would make regulatory or standards changes, if you will, on the COP's side. And this really was a win for hospices because this does align again with the changes that are already in the certification of terminal illness payment regulations and the medical director COPs regs. So we want to make sure that the message here is that CMS has listened and clarified that not only the physician member, not just the medical director, the confusion and the disconnect we remember that from several years ago Absolutely the disconnect or difference between discrepancy between the conditions of payment and the conditions of participation, between the conditions of payment and the conditions of participation. So any member, any physician, member of the hospice physician, member of the hospice interdisciplinary group, not just the medical director or the physician designee can complete the certification.
Speaker 1:So, kim, there's another one in terms of the other text update, and what we got on the final rule wasn't what was proposed, and that's actually a plus for providers as well, don't you think?
Speaker 2:I do, and In this particular change, cms actually did identify that the reason for the change from the proposed rule to the final rule was in response to comments.
Speaker 2:We, you know, say anything else that this is another example of the importance of providers and the industry submitting comments to any of the proposed rules, because you know there are changes.
Speaker 2:So, in this particular case, with the face-to-face attestation, they originally corrected an inadvertently regulatory admission from the 2012 hospice final rule to restore the signature and date requirements for the face-to-face attestation. And then the second part, which is also this is the area that was, or the section that was, finalized based on comments. They finalized changes to reduce administrative burden by eliminating the requirement that the attestation must be a separate and distinct document and then clarifying that the attestation requirement may be fulfilled. Requirement may be fulfilled not only as either a clearly titled section of an addendum to the research, but also part of a signed, dated clinical note within the clinical record. So this is really important and probably you know the area that organizations hospices are really going to need to look at in terms of their own internal processes as well, as you know, within their EMRs, to make sure that they can make these changes, but ultimately this is a win for hospice.
Speaker 1:Yeah, you know I agree with you. One on the comments. Comments can absolutely sway CMS and we've seen this. You know the proposed was completely different than what we got on the back end. So no matter let's use the word onerous today throughout this podcast no matter how onerous it may seem to put together a comment letter, you know it can be to everybody's benefit if everybody weighs in and not only saying that you don't think this is maybe a good idea, but providing reasons for why it is not a good idea and alternatives for CMS to consider when you do write that comment letter. This is a complete win, I think, for providers for sure.
Speaker 2:Absolutely, Jennifer. I know there were also updates related to hospice quality reporting and, of course, hope. Do you want to?
Speaker 1:share some insight there. Yeah, and again, I think think for me everything was expected and I know there were some rumors going around when the proposed rule first posted and then you know people that did comment back, shared with me that they were asking for a delay of the implementation. But I didn't feel like CMS was going to do that and they didn't. So we are on track for an October 1 implementation of the HOPE assessment tool, which is just a couple of weeks away. So hopefully everybody is, you know, being busy as bees in order to be ready for that implementation. Also, they did reiterate in that quality area that the HOPE quality measures, which are two of them, would not be implemented earlier than fiscal year 2028, because they need to really collect at least four quarters of data, to look at that data and analyze it to see if it ticks all the boxes for public reporting of those measures. And they'll keep us in the loop per the final rule about what is happening with the data analysis and when they think they will go ahead and start public reporting of those two measures. Also, they did state that they would provide that communication most likely in sub-regulatory channels, versus waiting for the next year's rule to communicate what they're doing with that, and there might be something in next year's proposed rule, an update or what have you, but I would expect sub-regulatory communication to be it. So that's why it's really important for providers to watch that HQRP web page, in the spotlight page, particularly to see when things are changing and updated.
Speaker 1:Now, the big thing here, kim, is that the submission of HOPE data is going to be via the I-KEY system. The HIS submission is in the KEY system. So it is extremely important and I'm saying this as something organizations have got to get on. They've got to jump on this if they absolutely have not jumped on it yet. And actually the suggested date for doing your application and registering in iKeys was on September 10th.
Speaker 1:So if it's after September 10th and you're listening to this and you haven't already established your account, go there today, as soon as you you're listening to this and you haven't already established your account, go there today, as soon as you're finished listening to this podcast, and do your registration in iKeys, because iKeys will stop accepting records for HIS on the 30th of September and start accepting HOPE on October 1 through I-Keys. But it also was stated in that final rule that any hospice admissions and discharges that occurred prior to October 1, including any corrections you have, up until February 5th of 2026 if you have to make corrections to those records. So for me, reading that rule, I would say that was the big enchilada. For me in there was the hope content of the rule, absolutely.
Speaker 2:Yep, I just want to give a shameless plug for you, jennifer, and for CHAP and for the outstanding blog series that you have put in, that you prepared and presented over the past. You know several episodes or several blog postings specifically related to hope implementation. So, along with any you know, cms education and any other training that folks may receive your blog, jennifer's blog post or the CHAP blog post that series is extremely important and really provides some valuable down-to-earth information in terms of implementation. Well, thanks, kim Sure.
Speaker 1:The only other thing, oh, one thing before we move on. We actually just posted our last pre-implementation blog, so that is on our website now and we developed a new what we're calling a Hope Quick Tool that has all of the important links you need in one document. Actually, it's not a document, it's right on our webpage. So you just go to that tool and you click and it takes you to all the education and guidance and manuals and tools that CMS has put out regarding the HOPE tool, rather than you going to separate web pages in CMS to search for all this stuff. So that's up and available right now.
Speaker 2:That's excellent and absolutely hospices should take advantage, because there is so much information flying around and, frankly, we're under the gun and folks will continue to have questions as hope is implemented. The one final thing I want to remind folks of is the fact that, at least at this point in time, cms is implementing the 4% reduction in hospice quality reporting for the future, a subsequent payment year if the 90% compliance threshold for submissions acceptable submissions is not met. So there is no and, jennifer, I'm saying this so that you can just validate this there is no delay. There is no, at this point in time, there is no delay in that requirement. So once the HIST, once we switch over from HIST to HOPE, that compliance threshold still remains his to hope that compliance threshold still remains.
Speaker 1:Yep, it's still 90%, and that's an aggregated 90% of accepted records. So you can submit records till the cows come home, but if they're not accepted, then you have a problem when it comes time for CMS to calculate your compliance. So thanks, kim, for mentioning that Nobody can take a 4% cut in these days and times. I think the last thing that we want to talk about and I'm going to throw the ball to you, kim is there were some requests for information in that proposed rule and you know how did those come out on the back end for the final rule.
Speaker 2:So, generally speaking, the advanced digital quality measurement for the hospice quality reporting, as well as the comments on the variety of questions related to the status of IT and technology in hospice, along with input on the importance, relevance, appropriateness and applicability of the concepts under consideration, which include interoperability, well-being and nutrition. In those cases, there were no comments or final rule or final decisions that were provided in the rule. So what that means, at least at this point, is that CMS in those cases are holding on any further action. Jennifer, I just want to again just have you clarify. That does not mean that they can't, in subsequent proposed rules, add or basically consider the comments or revisit these particular RFIs. Am I correct on that?
Speaker 1:Yeah, no that's absolutely right. They absolutely can swing around and I think definitely I would expect them to swing back around to the interoperability, because that seems to be one thing that is a huge focus up at CMS, and it's not just for hospice, it's for everybody, right. So I would expect to see more on that in future rulemaking.
Speaker 2:And I would say I would agree with that as well as the deregulation request, rfi In both of those cases there's much more broad implications, not just for hospice but for all CMS settings. And specifically regarding the deregulation request, there was no feedback or information provided in the hospice final rule. But we also know that that is a separate RFI. So we would fully expect that any feedback or determination regarding that the deregulation aspect of the RFI likely will come or can come in a separate rule, I would assume.
Speaker 1:Yeah, I think that's absolutely possible, for sure. So, as we wrap up here, kim, what would you say providers should be doing now that we have this final rule and we're only a few weeks from October 1, the start of the fiscal year 2026?
Speaker 2:Yes, absolutely. I mean certainly read the final rule. I think we say that every time right, make sure that everyone is clearly understanding what the changes are. Certainly receive information as we are imparting it, but also your national associations and the state associations are your partners in making sure that you have the information and industry experts. Absolutely looking at evaluating your own internal impact of the final rule, whether it's the wage index or how that the wage index or the, you know how that's going to impact you. Certainly, hope, as you have said. I mean we can't underscore enough the importance of readiness related to hope, and those are the regulatory changes that we discussed. Again from a CHAP perspective, I know that you and the quality team, and certainly my team, will work together to update any standards language that are needed from a CHAP perspective, and we will educate our own site visitors. You know on what the changes are and what they are to be looking for, but organizations do need to again evaluate their own processes and policies to affect these changes.
Speaker 1:You read my mind. I was just going to say policies too, kim. Right, absolutely All right. So what we are hoping, in addition to listening to this podcast, that you would read the summary we did put out about the final rule and also you look at anything from CMS that might be available in the days to come as they push things out from the final rule, meaning that there may be some additional guidance on the regulatory text changes or on the regulatory text changes or, who knows, even some more hope tidbits as we're inching our way towards that implementation date. Any final thoughts for us, kim?
Speaker 2:No, I think I believe that hospices are. I'd like to believe that hospices are well on track. You know certainly hope, I think, is the biggest challenge. You know the regulatory changes, again operationally. You know making sure that they are ready for them, as well as the financial impact of the effect of the. You know what the wage index changes are. But I think that you know. I feel very positive in speaking with hospices about their ability to be able to implement, successfully implement all of these final rule requirements, likely with some ongoing support and guidance and continued feedback from the industry and from CMS regarding hope.
Speaker 1:Well, thank you so much, my good friend. It's always a pleasure to talk quality and compliance with you, for sure.
Speaker 2:Absolutely.
Speaker 1:Thank you, oh, you're welcome and thanks to all of you, as usual, for taking time out of your day to listen to our podcast. So, from Kim, me and the entire CHAP staff, keep your quality needle moving forward, stay safe and well, and thanks for all you do. Thank you.
