2026 Hospice Final Rule Released

The 2026 Hospice Final Payment and Regulatory Update Rule was published on August 1 and aligns closely with what was outlined in the proposed version, confirming anticipated provisions and updates.

RATE ADJUSTMENT

The 2026 final rule includes a 3.3% Market Basket increase, which, after applying a 0.7% productivity adjustment, results in a net rate increase of 2.6%. This is slightly higher than the originally proposed 2.4% increase.

Additionally, the Hospice Cap will be adjusted by the same percentage as the rate update. As a result, the Cap has been increased by 2.6%.

REGULATORY LANGUAGE UPDATES

CMS has also provided important clarifications within the regulatory language concerning Hospice patients. Notably, it has been confirmed that both the medical director and any Hospice physician who is a member of the interdisciplinary group (IDG) are authorized to refer a patient for Hospice admission or verify that the admission criteria are met, thereby certifying the patient for Hospice care.

FACE-TO-FACE ENCOUNTERS

In the Proposed Rule, CMS provided background and regulatory language regarding the Face-to-Face encounter requirement, emphasizing that the attestation is a separate and distinct element of the recertification process. They also clarified that the signature of the provider who conducts the Face-to-Face encounter must include a date. While it was commonly assumed and generally treated as necessary for the signature to be dated, the previous regulatory language only mentioned a required signature. This clarification now officially confirms that the signature must be dated.

With respect to the separate and distinct attestation or addendum to the recertification, the final rule from CMS clarifies that the attestation requirement is complete if there is a Face-to-Face encounter note specifically identified as the Face-to-Face encounter. This note must include the necessary clinical assessment requirements, be signed and dated by the practitioner who conducted the encounter, and the note being incorporated into the patient’s medical record must meet the attestation requirements that the Face-to-Face encounter took place.

HOPE UPDATES

Additionally, it has been confirmed that the implementation of HOPE will begin on October 1, 2025. No delays or extensions are planned at this time. Starting on that date, HOPE will begin to affect compliance with the Hospice Quality Reporting Program.

The period from October 1 through December 31 will be included in the compliance calculations for the Hospice Quality Reporting Program. During this time, at least 90% of all required HOPE assessments must be submitted to the database within 30 days of the designated timeframe for each assessment.

Be sure that your HOPE training is already underway and continues consistently to ensure full readiness for implementation on October 1, 2025. CMS released additional HOPE-related educational materials a few weeks ago you can use to educate your staff.

Healthcare Provider Solutions offers a HOPE training series that provides additional support and supplemental training. For more information regarding our HOPE training series, please reach out to us.

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