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October 15, 2025: Missed vs. Refused Visits - Do YOU Know the Difference

Recent discussions in homecare social media groups have highlighted confusion about documenting missed and refused visits in home health care. The Centers for Medicare & Medicaid Services (CMS) provides distinct guidance for each, as outlined in the Conditions of Participation (CoPs) under 42 CFR §484.60 and §484.75. Proper documentation is critical to ensure compliance, patient safety, and uninterrupted payment.

Missed Visits
A missed visit occurs due to organization-related issues, such as staff illness, scheduling errors, or patient absence. The home health organization is responsible for staffing challenges, including covering for staff who are ill or on vacation. Documentation for a missed visit should include:

  • The reason for the missed visit.
  • Attempts to contact the patient.
  • Notification to the clinical supervisor.
  • Assessment of the impact on the patient’s status or plan of care (POC).

If the HHA reschedules and completes the visit within the organization’s designated “Medicare Week” and the visit aligns with the physician’s ordered frequency, it is not considered a missed visit. Physician notification is NOT necessary. For example, if a physical therapist finds the patient absent on Monday but completes the visit later that week, no missed visit documentation or physician notification is required.

Refused Visits
A refused visit occurs when a patient or caregiver declines a scheduled visit. Documentation must clearly capture:

  • The reason for refusal (if provided).
  • Evidence of staff educating the patient or caregiver about risks to clinical well-being (e.g. missed dressing changes or essential medications) on multiple occasions.
  • Attempts to identify and address the reason for refusal.

If the HHA cannot resolve the refusal, the organization must notify the patient's physician or allowed practitioner to discuss next steps for care coordination.

Physician Notification
For both missed and refused visits, the physician must be notified, though a written order is not required. Notification ensures alignment with the physician-ordered POC, as mandated). Clinical managers must coordinate care per 42 CFR §484.75(b)(3). Failure to document appropriately may result in survey deficiencies, risking patient safety and payment denials.

Tips for Success:

  1. Standardize Processes: Develop clear policies distinguishing missed and refused visits, specifying documentation and notification requirements.
  2. Leverage Technology: Use electronic medical record (EMR) systems with alerts or templates to ensure accurate visit status selection and completion of follow-up fields. Require same-day communication to clinical supervisors to assess impacts on patient safety or outcomes.
  3. Educate Patients: At admission and recertification, inform patients about the importance of visit adherence to prevent delays in healing or coverage issues.
  4. Monitor Trends: Track missed and refused visits monthly through Quality Assurance and Performance Improvement (QAPI) to identify patterns and implement targeted interventions.
  5. Ensure Physician Communication: Document repeated issues and physician instructions to maintain care coordination and survey readiness.

October 8, 2025: Government Shutdown - Stepping UP to the Challenge

As a Nurse Executive with decades of experience navigating government shutdowns I’ve witnessed just how the disruptive ripple effects on homecare and hospice services can be. In the short term. However, at first we will primarily see administrative hurdles rather than halting Medicare payments outright. Be aware, since Medicare is a mandatory program-there will be NO stopping of payments. According to a recent CMS MLN Connects bulletin, Medicare Administrative Contractors (MACs- like CGS, NGS, and Palmetto, etc.) will, likely, hold claims for up to 10 business days. These ‘holds’ may lead to potential cash flow delays. While organizations can still submit claims, the holds are a stark reality. Non-essential functions, like provider enrollment, audit resolutions, regulatory oversight, etc., are likely to slow down or pause due to government layoffs.

In the medium to longer term, remember, pandemic-era flexibilities have expired. This presents a bigger challenge, requiring agencies to revert to pre-COVID care models. As you likely know, on October 1, 2025, telehealth waivers ended. This has stopped homecare and hospice providers from using telehealth and requiring in-person homecare and hospice recertification. This change has increased operational costs for travel and staff time.

Tips for Providers Stepping Up to the Challenge:

  1. Cash Flow Management: Organizations should anticipate delays in claims processing. Organizations should look to securing a line of credit or maintaining a cash reserve to cover operational costs during the 10-day hold period. Tap into some of the Channel Partnerships resources with AXXESS for guidance.
  2. Prioritize Claim Submissions: Organizations should continue submitting claims promptly to avoid backlogs. For Hospice organizations, be sure to encourage training for HOPE through Axxess Training and Certification to ensure claims are filed properly to avoid reviews that will, again, resurface once the shut-down is over.
  3. Adapt to Telehealth Restrictions: Organizations will need to reallocate resources to support in-person visits. In particular, hospice organizations should explore private pay or alternative funding for telehealth in non-rural areas. It’s a really good idea for Hospice organizations to be familiar and contact any in-home physician practices in local areas for support.
  4. Communicate with Staff: Organizations should be completely transparent in the communication with staff to manage workload expectations.
  5. Watch Legislative Updates: Deb Hoyt and our Public Policy folks keep us updated on a regular basis. Be sure to share timely updates with organizational providers. Stay informed through resources like the National Alliance for Care at Home. The Alliance frequently provides updates on retroactive fixes or waiver extensions to adjust operational plans. For instance, on Friday, October 3, the Alliance informed providers that the MACs will continue to accept Face to Face for claims filed after the October 1, 2025 that were performed using telehealth if they occurred within the 90 days prior to the start of care (SOC) date. Organizations must document this clearly and monitor for any CMS updates during the shutdown, as retroactive extensions could affect processing.

October 1, 2025: Last Call for HOPE - Avoid the Risk of "Hallucinations"

As a seasoned nurse executive with multiple decades in post-acute leadership (including the introduction of OASIS for home health), I cannot overstate the gravity of the impending shift to the HOPE assessment-this week. This CMS required tool is not an option. HOPE requires precise data collection at admission, during up to two HOPE Update Visits (HUVs) within the first 30 days, and at discharge. Information from these required assessments drive quality reporting, care planning, and payment integrity/compliance. I've heard alarming whispers from colleagues across the industry who have dismissed the timeline and are tempted to cut corners by turning to AI tools like ChatGPT for staff training. Let me be crystal clear, this is a very dangerous path that could jeopardize patient care, regulatory compliance, and your hospice organizations survival.

AI may seem like a quick fix for explaining HOPE's items ( such as symptom scales, patient/family interviews, etc.) but it carries unacceptable risks. Among these include, but are not limited to, a phenomenon of "hallucinations." These are not simple glitches. AI hallucinations generate convincingly plausible but entirely fabricated information This practice could potentially mislead your team into botched assessments, erroneous data submissions, and catastrophic audit failures under the HQRP.

The dangers don't stop at hallucinations; they cascade into profound compliance pitfalls, where AI routinely misses unique CMS updates or hospice-specific guidelines. This practice invites issues of False Claims Act violations, denied reimbursements, and legal battles over care necessity. Privacy breaches when putting case scenarios into non-secure AI platforms, risk HIPAA violations and steep fines that could cripple your operations.

In addition, AI's inherent biases often results in flawed training data. Dependence on AI for Hope training or practice erodes genuine staff competency, breeds inefficiencies in workflows, and muddies accountability in potential liability claims, leaving your team exposed. I urge you, as a nurse executive who has navigated these regulatory minefields for many years do not gamble with AI for this critical training. Prioritize official CMS resources, such as their detailed guidance documents and training modules Utilize AXXESS Training and Certification HOPE training, which align directly with CMS standards. Insist on human oversight for every step, and confine AI—if used at all—to superficial, non-clinical issues. Our patients and families deserve nothing less than compliant, compassionate, and error-free care in their final moments. 

Remember, “Competency and Confidence=Compliance”

3 Tips for Training Last Minute Training

  1. Prioritize Official Sources Immediately: Dive straight into AXXESS HOPE resources, including the HOPE training videos, and webinars. Avoid generic searches—focus on AXXESS and cms.gov for accurate, up-to-date materials to ensure your team is clear on the essentials.
  2. Schedule Intensive, Focused Sessions: Block out dedicated time blocks this week for virtual training. Break HOPE into digestible modules (admission data, HUV logistics) and use role-playing to reinforce learning, aiming for full staff coverage as quickly as possible.
  3. Implement Quick Accountability Checks: Assign mentors to quiz teams post-training using CMS sample scenarios. Track completion via simple checklists or EHR-integrated tools to identify and address gaps.

September 24, 2025: Hospice Care at Risk - The Looming End of Telehealth Face-to-Face Flexibilities

My friend and colleague, Raianne Melton, recently reminded me of the upcoming, scheduled, end of telehealth for Medicare-mandated face-to-face encounters in hospice care. Effective October 1, 2025, we face a major shift with far-reaching consequences for both providers and patients. Coincidentally, this date ushers in the HOPE assessment for patients putting even more pressure on hospice organizations.

For hospice providers, the return to in-person recertification visits for the third and subsequent 60-day benefit periods will intensify existing pressures. Staffing shortages, rising operational costs with the HOPE assessment, and travel demands will add to the strain. The combination of these two significant changes happening on the same day is unsettling. These changes create new challenges in scheduling and increasing the risk of delayed certifications that could jeopardize reimbursement. Telehealth has been a lifeline for rural and underserved communities for several years. These organization could be especially vulnerable, facing higher risks of provider burnout among physicians and nurse practitioners already stretched thin.

Patients may feel the impact even more acutely. Those with limited mobility, fragile health, or who live in remote areas will face significant changes. They will now be required to undergo in-person assessments, potentially exposing them to more discomfort, logistical barriers, and potential infection risks. Interruptions in timely recertification could threaten continuity of care.

This rollback of telehealth policy also erodes the equity gains. This policy was established during the pandemic to allow telehealth providers to confirm eligibility through secure, real-time audio-video interactions without sacrificing quality. By taking away this flexibility, Medicare risks widening disparities among vulnerable populations. These folks depend on consistent symptom relief and emotional support at life’s end.

As Congress debates solutions like the Telehealth Modernization Act, the hospice community is calling for urgent action to preserve access and protect patient-centered care. Without swift intervention, the loss of telehealth threatens to undermine the very principles of compassion and equity that hospice care is built upon.

Maxim Tips for Success:

  1. Contact your Representatives in Congress and explain the issues patient face as a result of this roll-back. Encourage consideration of the Telehealth Modernization Act.
  2. Begin looking at your scheduling of these face to face on site visits. Be sure to track carefully to avoid delays in care or recertification.
  3. Train staff in the new requirements within the next 10 days.
  4. Consider contracting with a visiting physicians practice to make home visits for face to face within the timelines required.
  5. Inform your patients of the upcoming change.

September 17, 2025: HOPE it up, Buttercup

Hospice agencies across the U.S. are facing a serious challenge: HOPE assessments are here, and many teams aren’t ready. Some staff are misinformed, others feel overwhelmed, and too many organizations are still waiting to act.  Experts report there are approximately 40% of hospice staff are NOT ready for HOPE.

Here’s the truth: if you don’t prepare, your patients, your staff, and your agency will all feel the impact.

HOPE (Hospice Outcomes and Patient Evaluation) is replacing the HIS document. HOPE has been designed to capture the full hospice experience—physical, emotional, and spiritual needs—while tracking outcomes over time. Just like OASIS in home health, HOPE gives CMS reliable data for public reporting, ensures transparency, and supports value-based care.

If you’re not ready yet, here are five reasons to make training a top priority right now:

  1. Financial Risks
    Missing HOPE deadlines means losing money. Noncompliance brings a 4% cut in Medicare payments, plus higher overtime and admin costs when staff struggle with the tool. Remember-there are multiple HOPE assessment time points that are RN assessments ONLY.  LPN/LVN(s) will not be able to complete multiple required assessments.
  2. Regulatory and Compliance Risks
    HOPE has strict timelines. Admission assessments must be done within five days, and more are required throughout care-HUV-1 between 6-15 days of patients stay and HUV2  at 16-30 days of admission. Remember Symptom Follow-up assessments have a limited 2 calendar day limit   Missed or late assessments can bring survey citations, corrective action plans, or worse—loss of Medicare certification.
  3. Legal and Litigation Risks
    Skipping or mishandling HOPE puts patients at risk. Pain, falls, or hospitalization needs could be missed. Families may sue, and inaccurate data tied to billing could trigger False Claims Act violations
  4. Operational and Quality of Care Risks
    Poor data = poor outcomes. Public quality scores drop, referrals shrink, and patients lose trust. Staff also burn out fast when they don’t feel competent or supported.
  5. Strategic Risks
    HOPE data will drive the future of hospice: benchmarking, payer contracts, and preferred provider networks. Agencies that don’t adapt will be left behind.

 

Maxim Tips for Success

  • Train NOW, train often: Don’t wait—get staff practicing HOPE before October 1. AXXESS  Training and Certification has taken the lead in providing HOPE training for the industry.  Take advantage of this critical information. Remember the “3-C’s”-Competency and Confidence=Compliance.
  • Break it down: Teach one part at a time—admissions, follow-ups (HU1 and HU 2, Symptom Update Assessment(s), discharges—so staff don’t feel overloaded.
  • Use your EMR: Update templates and tools so HOPE fits naturally into daily work. You will find the AXXESS solution the most up to date EMR related to HOPE in the industry.  Remember, your EMR is a ‘tool” for documenting the information-your staff MUST be trained to enter the most accurate information possible.
  • Pick your champions: Choose “HOPE experts” on your team who can coach, answer questions, and support others.  Identify a ‘super-user’ for the EMR who has FULL ‘competence/confidence’ in the assessment tool. 


September 10, 2025: Homecare Heroes Unite - Rallying Against CMS's 2026 Payment Cuts

As a home care nurse executive with over 40 years of experience, I’m thrilled to dive into the electrifying fight for our industry’s future! As most of you know, in July, the  proposed Home Health PPS rule for 2026  dropped a jaw-dropping net 6.4% payment reduction—that’s a staggering $1.13 billion cut!  This includes a 4.1% permanent behavioral reduction, a 5% temporary recoupment, and a 0.5% outlier adjustment. Shockingly, these changes ignored skyrocketing inflation and crippling workforce shortages, threatening access to care, especially in rural communities, and pushing patients toward pricier hospital stays.

But hold on!! Our homecare community ROARED back like never before! By August 29, we flooded CMS with an unprecedented >950,000 comments!  This massive feedback from providers, clinicians, caregivers, and beneficiaries shows our unstoppable spirit and deep concern for our patients. I’m hoping that this massive outcry will shape a fairer final rule, expected to drop in late October.

And the excitement doesn’t stop there! Just this week, Capitol Hill lit up with bipartisan momentum!  Representatives Kevin Hern (R-OK) and Terri Sewell (D-AL) introduced the game-changing Medicare Beneficiary Home Health Access Protection Act of 2025 (H.R. 5142). This bill is a home health lifeline, demanding that HHS offset both the permanent and temporary payment cuts in 2026 and 2027, giving us time to fix proposed rule flaws, work on fraud prevention, and protect access to home health services. It’s immediate relief with a vision for long-term, sustainable solutions!

Let’s keep the energy soaring!  As nurse leaders, we must rally behind this homecare life-saving bill. Reach out to your local Representatives—email, call, or ask them to visit your agency and urge them to support H.R. 5142. Our mission is crystal clear: adapt, advocate, and champion home health as the cost-effective, compassionate cornerstone of care for our most vulnerable patients. Let’s make history together!


September 3, 2025: HOPE and iQIES

As a nurse executive, I cannot emphasize enough how critical it is for hospice providers to complete their iQIES registration in advance of the upcoming HOPE tool launch on October 1, 2025.

Be aware that each hospice agency must designate a “Provider Security Official” (PSO), who is responsible for initiating the registration process through the iQIES portal. Once the PSO is approved, they can authorize other users within the organization. Registration requires accessing the CMS iQIES website, creating a HARP (HCQIS Access Roles and Profile) account if one is not already in place, and submitting the required information for approval. There is a firm deadline for PSO registration of September 10, 2025. Remember, without a completed registration, agencies will be unable to submit HOPE data. Nor will the hospice organization be able to access necessary quality reporting tools, which could directly affect compliance. Now is the time to double-check that you actually have a PSO identified and that your PSO has applied AND has received confirmation of active access.

The consequences for missing this deadline are significant. Hospices failing to register for iQIES will not be able to participate in the reporting of HOPE data beginning October 1. This is a required factor of the Hospice Quality Reporting Program (HQRP). The non-compliance with HQRP will lead to a 2% reduction in the Annual Payment Update (APU) This penalty will directly reduce Medicare reimbursement. But even beyond reimbursement, lack of timely registration will put your hospice organization at risk for damage to your hospice reputation in the community since performance scores that are publicly displayed on Care Compare will not be available. My strong recommendation is that leadership teams prioritize this process immediately. Be sure to assign accountability for tracking progress, and ensure that all necessary staff are registered well before the September 10 deadline.

Maxim Tips for success:

CMS has listed these 4 ‘steps’ for Hospice organizations to receive access to iQIES:

  1. Identify at least one individual who will be the PSO, though CMS recommends at least 2.
  2. Register the PSO for the iQIES login credentials within the Healthcare Quality Information System (HCQIS) Access Roles and Profile (HARP) system at: https://harp.cms.gov/register
  3. After Identify proofing your MFA (Multi-Factor Authentication) is complete, you can access IQIES at the following URL:https://iqies.cms.gov/ using your HARP ID and password (completed in step 2 above) to indicate your PSO role request for YOUR specific provider CCN.
  4. Once the PSO role request has been submitted AND approved, you will receive notification via email. At this point you will be one of the designated PSOs for your CCN and have authority to approve/deny subsequent requests for access of various role types to your provider’s CCN.


August 27, 2025: Innovation Meets Advocacy - The New Era of Home Care

As a clinician, I was thrilled to learn that the Research Institute for Home Care (RIHC) and the National Alliance for Care at Home have formed a new affiliation agreement, effective immediately. This partnership is a game-changer for home care clinicians, combining RIHC’s research expertise with the Alliance’s advocacy resources to advance care practices and elevate our field. For us, this means access to evidence-based research that can refine clinical guidelines, spark innovative care delivery methods, and improve patient outcomes. By amplifying clinicians’ voices in national discussions, this collaboration could secure more funding for studies that highlight home care’s ability to save costs, enhance patient health, and reach underserved communities, solidifying its vital role in healthcare.

The RIHC, as a new entity, enhances the work of MedPAC, which provides Congress with broad, policy-level Medicare insights focused on cost control and payment structures. Unlike MedPAC, RIHC takes a clinician-driven, research-oriented approach, diving deep into home care-specific data. Through its affiliation with the National Alliance, RIHC can produce detailed studies on cost savings, health improvements, and access for underserved populations. These actionable, sector-specific findings complement MedPAC’s broader analyses, offering Congress and stakeholders clear evidence of home care’s effectiveness and reinforcing its critical place in the healthcare system.

Maxim Tips for Success

  1. Leverage Evidence-Based Research for Better Patient Outcomes: Stay up to date with partnerships like your State Associations, RIHC, and the National Alliance to access updated clinical guidelines and innovative care models. Using data-driven insights from funded studies, you can be a part in showing how home care reduces costs and improves health, making your practice more effective and advocating for its pivotal role in healthcare.
  2. Embrace Healthcare Technology to Streamline Workflow: Follow experts like John Olajide by adopting tools like Axxess’s EMRs to streamline operations and support clinicians. These systems simplify documentation, enhance regulatory compliance, and reduce paperwork, enhances education and allows you to focus on patient care and improve coordination with other providers.
  3. Amplify Your Voice Through Advocacy and Collaboration: Engage with relationships like this affiliation to ensure the clinicians’ perspectives shape national discussions. By supporting unified advocacy efforts, you can push for increased funding and supportive policies, positioning home care as a cornerstone of healthcare and keeping your practice competitive.

August 20, 2025: The United Health-Amedisys Merger Shake Up

Last week there were new developments in the merger between UnitedHealth and Amedisys that represents a significant consolidation in the home health and hospice sector. This is primarily driven by UnitedHealth's strategy to expand its Optum Health division amid growing demand for cost-effective, home-based care. In an effort to reduce antitrust concerns raised by the Department of Justice, UnitedHealth has agreed to divest 164 locations, aiming to preserve competition, patient access, and fair wages for healthcare workers. This deal, has an extended timeline potentially lasting until December 31, 2025, and underscores the regulatory hurdles in healthcare mergers. Overall, it signals an accelerating trend toward industry consolidation, where well-capitalized entities like UnitedHealth gain economies of scale, potentially enhancing efficiency and investor interest, but at the expense of smaller organizations who may struggle with reduced referrals, staffing shortages, and negotiation power with payers.

While the merger offers opportunities for mid-sized operators to acquire divested assets and scale regionally, it intensifies pressure on smaller. independent and nonprofit providers, risking their being disregarded in a landscape dominated by private equity-backed consolidators. However, if you are a high-quality small provider this could differentiate your operation through localized, flexible care models, that may position the organization as an attractive acquisition target for both homecare and hospice. This development reinforces the overall attractiveness of home health for investors, but those independent operators will need to navigate financial challenges and competitive shifts to avoid erosion of market share. 

Tips for Success in Small and Medium Homecare and Hospice Providers

  1. Explore Purchasing Opportunities: If you are in the market to grow your business you might want to take a look at the 164 divested locations. Mid-sized providers may find these assets ideal for expanding regional footprints without starting from scratch.
  2. Emphasize Localized Strengths: Highlight your agility and community-focused care to differentiate from larger entities; build strong local reputations to secure patient referrals and partnerships with hospitals or payers. Take a look at the many Axxess Channel Partnership’s for sources of unique programs that might enhance your current offerings.
  3. Strengthen Financial Resilience: Seek alternative funding sources, such as grants for nonprofits or strategic alliances, to bolster capital structures and withstand negotiation pressures from insurers and competition for staff. Take a look at the Axxess Homecare Survival Kit for ideas on reducing cost and making your organization more efficient.
  4. Adapt to Regulatory Changes: Watch the industry news. Stay informed on DOJ plans and merger timelines to anticipate market shifts; be sure to invest in compliance and technology to maintain competitiveness in a consolidating industry. Axxess Training and Certification has multiple resources available for improving and maintaining compliance.
  5. Focus on Niche Markets: Look for specialized services, such as hospice for underserved populations, to leverage your local reputation advantage for sustained viability. Connecting with Channel Partnerships for programs such as Zing Performance for clients with cognitive impairments will put your organization front and center as we work to improve Value Based Purchasing scores and patient outcomes.

August 13, 2025: Bridging the Digital Divide - Helping Caregivers Use Online Training

Family caregivers often step into challenging roles, managing chronic illnesses, disabilities, or age-related needs without formal training. Online tools like Axxess Caregiver University offer free, self-paced courses on topics such as medication management, dementia care, and stress reduction. These resources can save time, improve patient education, and enhance outcomes. However, many caregivers—especially older adults or those from underserved communities—struggle with the digital literacy needed to use these platforms. Nurses and therapists play a vital role in helping caregivers overcome this barrier, ensuring they can confidently use online training to provide better care.

Why It Matters: A recent McKnights article, “Why Mobile Micro-learning is the Future of Caregiver Training,” highlights the power of bite-sized, accessible online learning. Axxess Caregiver University, available through the Training and Certification site, is a free resource designed to empower caregivers. Yet, without guidance, some caregivers may feel frustrated or isolated when navigating digital tools, leading to suboptimal care. By teaching caregivers how to use these platforms, you can improve their skills, boost patient satisfaction, and make your visits more efficient.

Tips for Success

  1. Check Their Tech Comfort Level Start by asking caregivers about their experience with smartphones, computers, or online platforms. For those with limited digital skills, focus on basics like logging into Axxess Caregiver University or navigating to a course. Tailor your approach to their needs to build confidence.
  2. Break It Down Into Small Steps Use short, focused sessions to teach the platform, following micro-learning principles. For example, show caregivers how to access one module, like medication management, and let them practice before moving on. This prevents them from feeling overwhelmed and builds mastery.
  3. Offer Hands-On Support During visits, guide caregivers through Axxess Caregiver University step-by-step. Demonstrate how to log in, find courses, and track progress. Provide simple handouts or visual aids for them to refer to later, especially for those less familiar with technology.
  4. Show Empathy for Challenges Acknowledge that learning new technology can be frustrating, especially for underserved or older caregivers. Offer patience and encouragement, and connect them with local resources like libraries or tech workshops to further support their learning.
  5. Highlight the Benefits Explain how online training saves time and improves caregiving. For example, show how Axxess Caregiver University’s dementia care modules offer practical tips to make daily tasks easier. Emphasizing these benefits motivates caregivers to engage with the platform.

Moving Forward: As nurses and therapists, you’re uniquely equipped to help caregivers master online training. By incorporating digital literacy into your assessments, you can guide caregivers to use tools like Axxess Caregiver University effectively. This not only enhances their skills but also improves patient outcomes, increases satisfaction, and streamlines your teaching during visits. Start today by assessing caregivers’ tech skills and introducing them to these valuable resources.

Source: McKnights, “Why Mobile Micro-learning is the Future of Caregiver Training” Aug. 6, 2025

August 6, 2025: Hospice Final Rule Drops

CMS released the FY 2026 Hospice Wage Index and Payment Rate Update, Hospice CoPs Updates, and Hospice Quality Reporting Program (HQRP) final rule on August 1, 2025 (effective October 1, 2025). This rule includes a final hospice payment update of 2.6% (an increase from the proposed 2.4%), that is estimated to be an aggregate increase of $580 million in Medicare payments to hospices for FY 2026 compared to FY 2025. We are providing you with an abbreviated summary here. By focusing on preparation Axxess Training and Certification HOPE training, hospice providers will mitigate burdens while ensuring confidence, competency and compliance.

The Alliance welcomed some regulatory relief but criticized the payment update as insufficient amid inflation, workforce shortages, and rising costs. They also expressed disappointment over the lack of delay in HOPE implementation and urges CMS to provide flexibility during the transition. However, we must note that this date does not appear to be firm. As a footnote in the table of HOPE dates to be aware of, it clearly states “These dates are subject to change based on the quality and reportability of the data as determined based on CMS analyses;……….” source 

1. Hospice Payment Update and Rates: 

  • Payment Update Percentage: Finalized at 2.6% (up from the proposed 2.4% due to updated economic forecasts). This applies to all four levels of care: Routine Home Care (RHC), Continuous Home Care (CHC), Inpatient Respite Care (IRC), and General Inpatient Care (GIP).
  • Final FY 2026 Payment Rates (for hospices submitting required quality data):
    • RHC (Days 1-60): $225.79
    • RHC (Days 61+): $178.50
    • CHC: $1,620.15 (hourly rate: $67.51)
    • IRC: $523.57
    • GIP: $1,207.52
  • Rates for non-compliant hospices (failing HQRP requirements) are reduced by 4 percentage points, resulting in a -1.4% update.
  • Hospice Cap Amount: Updated to $34,806.11 (a 2.6% increase from FY 2025's $33,950.67), prorated for partial-year beneficiaries.
  • Impact Analysis: Overall payments increase by $580 million. Rural hospices see a 2.6% increase, urban ones 2.7%. Non-profit hospices gain 2.2%, for-profits 3.0%. Small hospices see 1.8%, while large ones see 2.7%. 

2. Changes to CoPs:

  • Admission to Hospice: Amends §418.25 to allow the physician member of the hospice interdisciplinary group (IDG) to recommend admission, aligning with certification requirements in the CoPs.
  • Face-to-Face Attestation: Clarifies §418.22(a)(4)(i) to require the attestation include the encounter date, performer's signature, and signature date. Allows a signed clinical note to serve as the attestation if it meets requirements, reducing burden.
  • Telehealth Extension: Extends telehealth for face-to-face recertification encounters through September 30, 2025. 

3. Hospice Quality Reporting Program (HQRP) Updates: 

  • HOPE Tool Implementation starts on October 1, 2025, replacing the HIS tool. Public reporting will begin no earlier than FY 2028.
  • Compliance: 90% timeliness threshold for submissions; 4% APU reduction for non-compliance starting FY 2024
  • System Transition: Shifts from QIES/CASPER to iQIES; training and resources available. 

Tips for Success: Navigating the FY 2026 Hospice Rule 

To help hospice providers adapt effectively, here are practical tips based on the Rule's changes and sector feedback:

  • Prepare for Payment Adjustments: Review your FY 2025 utilization data against the new wage index to forecast revenue. Small or rural hospices should model the 5% cap's impact and explore cost efficiencies, such as optimizing staffing for higher-acuity patients to maximize the 2.6% update.
  • Implement HOPE Seamlessly: Get started with Axxess Training and Certification for HOPE. Watch for AXXESS live training at many State or National Associations. The CMS guidance manual and materials are expected late summer 2025. Test workflows for admission, update visits, and discharge submissions via iQIES.
  • Leverage Regulatory Relief: Update policies to allow IDG physicians to recommend admissions and use signed clinical notes for face-to-face attestations— this will reduce documentation burden. Extend telehealth for re-certifications through September 2025 to maintain access, especially in rural areas. Be sure to change policies when this is no longer effective.
  • Enhance Quality Compliance: Ensure 100% CAHPS participation (unless exempt) and track claims-based measures. Use iQIES reports to monitor submissions; non-compliance could mean a -1.4% rate cut.
  • Address Operational Challenges: Amid inflation concerns, negotiate contracts for supplies/IT and invest in workforce retention utilizing Axxess EMR and, specifically, Axxess Training and Certification.

July 27, 2025: Hospice "In The Line Fire"

In response to a surge in Medicare hospice utilization—totaling over $27 billion in FY 2024 for 1.8 million beneficiaries—CMS has ramped up oversight to combat fraud and abuse in the hospice sector. New efforts include the Provisional Period of Enhanced Oversight (PPEO) in high-risk states (AZ, CA, NV, TX), leading to 122 hospice revocations, and expanded prepayment reviews for existing providers. Nationwide site visits, streamlined disenrollment processes, and a Rapid Response Team have strengthened protections for Medicare beneficiaries, including reversing 358 inappropriate hospice enrollments. These measures reflect CMS’s intensified commitment to transparency, accountability, and safeguarding vulnerable patients.

Maxim Tips for Success: This, of course, comes on the heels of the entrance of the HOPE assessment tool, timing could not be worse for the industry. This could mean that HOPE assessments will be looked at more carefully very soon after initiating that new hospice assessment tool. No time to waste in becoming proficient!! Axxess has the training you need. Take a look at these Hospice Fast Facts from CMS.


July 16, 2025: Hot News!

I'm thrilled to share encouraging news about the home healthcare industry. Despite challenges, such as those in the Proposed Rule, the market is poised for substantial growth. A recent Meticulous Research report projects the global home healthcare market to grow from $343 billion in 2024 to over $1,006.4 billion by 2035, driven by an aging population and technological advancements. In the US, the market is expected to reach $317.9 billion by 2035, fueled by Medicare Advantage plans, telehealth infrastructure, and strategic acquisitions by companies like Amedisys and Optum. (source: Meticulous Research, "U.S. Home Healthcare Services Market," June 2025)

Maxim Tips for Success: While larger organizations may have advantages, mid-sized and smaller agencies like many of yours can thrive by adapting and innovating. By leveraging technologies like telehealth and remote care monitoring, we can fill care gaps that larger providers often miss. Hiring and retaining highly skilled, well-trained staff is critical to our success. We encourage everyone to explore Axxess Training and Certification programs to stay at the forefront of home healthcare education.


July 9, 2025: "All Payer OASIS"

On July 1, 2025 the "All-Payer OASIS" requirement began! This requirement mandates that Medicare-certified home health organizations collect and submit OASIS for all patients, regardless of payer source, except for those under 18, receiving maternity services, or only personal care/housekeeping. This change intends to provide CMS with a comprehensive view of care quality across all patients, no matter how they are paid (e.g. private pay, free care, ALL insurances, charity care, etc.). This will potentially influence future payment and quality policies. Organizations must update privacy notices, train staff, and ensure systems are complying, as non-Medicare/Medicaid data may impact outcome calculations and Home Health Value-Based Purchasing (HHVBP) models.


July 2, 2025: CMS Proposed CY 2026 Home Health Payment Reductions

Last week CMS released the much expected proposed CY 2026 Home Health PPS rule, projecting a 6.4% payment reduction ($1.135 billion) for home health agencies compared to CY 2025. Key points:

  • Payment Changes: 2.4% statutory increase offset by 3.7% permanent and 4.6% temporary budget neutrality adjustments, plus 0.5% decrease from updated Fixed-Dollar Loss ratio.
  • Policy Updates: Revised Face-To-Face encounter policy, Home Health Quality Reporting Program changes (removing COVID-19 and certain items), and new HHCAHPS survey starting April 2026.
  • VBP Modifications: Updates on digital quality measurement, future quality measures, and Value-Based Purchasing adjustments.
  • Impact: The National Alliance for Care at Home warns of potential provider closures, care deserts, and reduced patient access.