September 10, 2025 • 23 mins
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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Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Speaker 1 (00:15):
Greetings.
I'm Jennifer Kennedy, the Leadfor Compliance and Quality at
CHAP, and welcome to thissession of CHAPcast.
In today's session, we're goingto talk about the hospice
fiscal year 2026 final rule thatcame out at the beginning of
August of 2025.
(00:36):
And, of course, I have my goodfriend and colleague here to do
the chatting with me about allthings Hospice Final Rule Kim
Skian, and she is our VicePresident for Accreditation.
Hi Kim, how are you doing?
Speaker 2 (00:53):
Hi, jennifer, I'm doing really well.
I'm actually excited to talkthrough the Hospice final rule.
I was actually thinking aboutyou when I was reviewing and all
of your years of it's notperusing deep, diving with all
(01:14):
of the federal registers, allthe 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 alittle more comprehensive, if
you will, and easier than orless onerous.
I guess I would say yeah,that's it.
(01:38):
That's the word Less onerous.
Speaker 1 (01:40):
That's exactly it.
So when the proposed rule cameout earlier this year, I, you
know I always sweat to like, ohGod, what's going to be in it
and how many pages is it goingto be?
And 82 pages, that's nothing,right.
And I think you're right.
I think it was completely lessonerous than years past and I
(02:04):
think the, you know, the firstthing that we could start out
with is, in addition toproviding an overview of, you
know, the various provisions inthe rule.
But, kim, if you want to get usstarted about, you know some
good news, it's the paymentupdate.
Speaker 2 (02:23):
Yes, absolutely, and yep, I'm sorry, just as an
(02:52):
update.
Really, the best news, if youwill, from this with the payment
update is that there is anoverall 2.6% increase nationally
and the aggregate cap is$34,465.34.
It also is important to notethat your actual payment update
or payment change will be basedon your own MSA, your own I'm
sorry CBSA, to be able to makesure that you know that there
may be an adjustment up or down.
But overall, I would say thathospice at the moment and I'm
(03:14):
really going to knock on woodwhen I say this, you know is
faring overall much morepositively in terms of at least
having the opportunity to have arate increase.
Continue to have a rateincrease, given the environment.
Speaker 1 (03:32):
Yeah, I agree.
You know it is a fact that wecan look at that March MedPAC
report that comes out every yearfor Congress and you know, look
at that and it's usually thetiming is about a couple of
(03:55):
weeks before the proposedhospice rule posts.
But to get an idea of whatcould be coming in terms of
payment idea of what could becoming in terms of payment
either update or staying thesame or what have you.
But I'm very happy for hospiceproviders out there that it is a
2.6 bump in their rate.
(04:15):
We did have a couple ofregulatory text updates too, so
let's talk about those, kim.
Speaker 2 (04:23):
Sure.
Well, I think it's important tonote that the regulatory updates
that are published in the finalrule are not substantive in
terms of a regulatory languagechange and will not change the
intent of the regulation itself,just really further clarifies
and really supports increasingoverall or decreasing burden, I
(04:48):
guess I would say, for hospices.
So the first is the CMSfinalizing the proposal to add
the text or the physician memberof the hospice
interdisciplinary group tochanges that would include both
to the conditions of payment,the Medicare benefit policy
(05:11):
manual, and also we would makeregulatory or standards changes,
if you will, on the COP's side.
And this really was a win forhospices because this does align
again with the changes that arealready in the certification of
terminal illness paymentregulations and the medical
(05:36):
director COPs regs.
So we want to make sure thatthe message here is that CMS has
listened and clarified that notonly the physician member, not
just the medical director, theconfusion and the disconnect we
remember that from several yearsago Absolutely the disconnect
(05:57):
or difference betweendiscrepancy between the
conditions of payment and theconditions of participation,
between the conditions ofpayment and the conditions of
participation.
So any member, any physician,member of the hospice physician,
member of the hospiceinterdisciplinary group, not
(06:20):
just the medical director or thephysician designee can complete
the certification.
Speaker 1 (06:24):
So, kim, there's another one in terms of the
other text update, and what wegot on the final rule wasn't
what was proposed, and that'sactually a plus for providers as
well, don't you think?
Speaker 2 (06:40):
I do, and In this particular change, cms actually
did identify that the reason forthe change from the proposed
rule to the final rule was inresponse to comments.
(07:02):
We, you know, say anything elsethat this is another example of
the importance of providers andthe industry submitting comments
to any of the proposed rules,because you know there are
changes.
So, in this particular case,with the face-to-face
(07:25):
attestation, they originallycorrected an inadvertently
regulatory admission from the2012 hospice final rule to
restore the signature and daterequirements for the
face-to-face attestation.
And then the second part, whichis also this is the area that
was, or the section that was,finalized based on comments.
(07:50):
They finalized changes toreduce administrative burden by
eliminating the requirement thatthe attestation must be a
separate and distinct documentand then clarifying that the
attestation requirement may befulfilled.
Requirement may be fulfillednot only as either a clearly
(08:11):
titled section of an addendum tothe research, but also part of
a signed, dated clinical notewithin the clinical record.
So this is really important andprobably you know the area that
organizations hospices arereally going to need to look at
in terms of their own internalprocesses as well, as you know,
within their EMRs, to make surethat they can make these changes
(08:33):
, but ultimately this is a winfor hospice.
Speaker 1 (08:36):
Yeah, you know I agree with you.
One on the comments.
Comments can absolutely swayCMS and we've seen this.
You know the proposed wascompletely different than what
we got on the back end.
So no matter let's use the wordonerous today throughout this
(08:57):
podcast no matter how onerous itmay seem to put together a
comment letter, you know it canbe to everybody's benefit if
everybody weighs in and not onlysaying that you don't think
this is maybe a good idea, butproviding reasons for why it is
not a good idea and alternativesfor CMS to consider when you do
(09:22):
write that comment letter.
This is a complete win, I think, for providers for sure.
Speaker 2 (09:29):
Absolutely, Jennifer.
I know there were also updatesrelated to hospice quality
reporting and, of course, hope.
Do you want to?
Speaker 1 (09:40):
share some insight there.
Yeah, and again, I think thinkfor me everything was expected
and I know there were somerumors going around when the
proposed rule first posted andthen you know people that did
comment back, shared with methat they were asking for a
(10:03):
delay of the implementation.
But I didn't feel like CMS wasgoing to do that and they didn't
.
So we are on track for anOctober 1 implementation of the
HOPE assessment tool, which isjust a couple of weeks away.
(10:24):
So hopefully everybody is, youknow, being busy as bees in
order to be ready for thatimplementation.
Also, they did reiterate inthat quality area that the HOPE
quality measures, which are twoof them, would not be
implemented earlier than fiscalyear 2028, because they need to
(10:47):
really collect at least fourquarters of data, to look at
that data and analyze it to seeif it ticks all the boxes for
public reporting of thosemeasures.
And they'll keep us in the loopper the final rule about what
is happening with the dataanalysis and when they think
(11:11):
they will go ahead and startpublic reporting of those two
measures.
Also, they did state that theywould provide that communication
most likely in sub-regulatorychannels, versus waiting for the
(11:31):
next year's rule to communicatewhat they're doing with that,
and there might be something innext year's proposed rule, an
update or what have you, but Iwould expect sub-regulatory
communication to be it.
So that's why it's reallyimportant for providers to watch
that HQRP web page, in thespotlight page, particularly to
(11:53):
see when things are changing andupdated.
Now, the big thing here, kim, isthat the submission of HOPE
data is going to be via theI-KEY system.
The HIS submission is in theKEY system.
So it is extremely importantand I'm saying this as something
(12:22):
organizations have got to geton.
They've got to jump on this ifthey absolutely have not jumped
on it yet.
And actually the suggested datefor doing your application and
registering in iKeys was onSeptember 10th.
So if it's after September 10thand you're listening to this and
(12:44):
you haven't already establishedyour account, go there today,
as soon as you you're listeningto this and you haven't already
established your account, gothere today, as soon as you're
finished listening to thispodcast, and do your
registration in iKeys, becauseiKeys will stop accepting
records for HIS on the 30th ofSeptember and start accepting
(13:07):
HOPE on October 1 through I-Keys.
But it also was stated in thatfinal rule that any hospice
admissions and discharges thatoccurred prior to October 1,
including any corrections youhave, up until February 5th of
(13:27):
2026 if you have to makecorrections to those records.
So for me, reading that rule, Iwould say that was the big
enchilada.
For me in there was the hopecontent of the rule, absolutely.
Speaker 2 (13:42):
Yep, I just want to give a shameless plug for you,
jennifer, and for CHAP and forthe outstanding blog series that
you have put in, that youprepared and presented over the
past.
You know several episodes orseveral blog postings
specifically related to hopeimplementation.
(14:04):
So, along with any you know,cms education and any other
training that folks may receiveyour blog, jennifer's blog post
or the CHAP blog post thatseries is extremely important
and really provides somevaluable down-to-earth
information in terms ofimplementation.
(14:25):
Well, thanks, kim Sure.
Speaker 1 (14:28):
The only other thing, oh, one thing before we move on
.
We actually just posted ourlast pre-implementation blog, so
that is on our website now andwe developed a new what we're
calling a Hope Quick Tool thathas all of the important links
(14:48):
you need in one document.
Actually, it's not a document,it's right on our webpage.
So you just go to that tool andyou click and it takes you to
all the education and guidanceand manuals and tools that CMS
has put out regarding the HOPEtool, rather than you going to
(15:11):
separate web pages in CMS tosearch for all this stuff.
So that's up and availableright now.
Speaker 2 (15:17):
That's excellent and absolutely hospices should take
advantage, because there is somuch information flying around
and, frankly, we're under thegun and folks will continue to
have questions as hope isimplemented.
The one final thing I want toremind folks of is the fact that
, at least at this point in time, cms is implementing the 4%
(15:45):
reduction in hospice qualityreporting for the future, a
subsequent payment year if the90% compliance threshold for
submissions acceptablesubmissions is not met.
So there is no and, jennifer,I'm saying this so that you can
(16:05):
just validate this there is nodelay.
There is no, at this point intime, there is no delay in that
requirement.
So once the HIST, once weswitch over from HIST to HOPE,
that compliance threshold stillremains his to hope that
(16:26):
compliance threshold stillremains.
Speaker 1 (16:27):
Yep, it's still 90%, and that's an aggregated 90% of
accepted records.
So you can submit records tillthe cows come home, but if
they're not accepted, then youhave a problem when it comes
time for CMS to calculate yourcompliance.
So thanks, kim, for mentioningthat Nobody can take a 4% cut in
these days and times.
I think the last thing that wewant to talk about and I'm going
(16:52):
to throw the ball to you, kimis there were some requests for
information in that proposedrule and you know how did those
come out on the back end for thefinal rule.
Speaker 2 (17:06):
So, generally speaking, the advanced digital
quality measurement for thehospice quality reporting, as
well as the comments on thevariety of questions related to
the status of IT and technologyin hospice, along with input on
(17:27):
the importance, relevance,appropriateness and
applicability of the conceptsunder consideration, which
include interoperability,well-being and nutrition.
In those cases, there were nocomments or final rule or final
decisions that were provided inthe rule.
So what that means, at least atthis point, is that CMS in
(17:53):
those cases are holding on anyfurther action.
Jennifer, I just want to againjust have you clarify.
That does not mean that theycan't, in subsequent proposed
rules, add or basically considerthe comments or revisit these
(18:15):
particular RFIs.
Am I correct on that?
Speaker 1 (18:18):
Yeah, no that's absolutely right.
They absolutely can swingaround and I think definitely I
would expect them to swing backaround to the interoperability,
because that seems to be onething that is a huge focus up at
CMS, and it's not just forhospice, it's for everybody,
(18:40):
right.
So I would expect to see moreon that in future rulemaking.
Speaker 2 (18:45):
And I would say I would agree with that as well as
the deregulation request, rfiIn both of those cases there's
much more broad implications,not just for hospice but for all
CMS settings.
And specifically regarding thederegulation request, there was
no feedback or informationprovided in the hospice final
(19:08):
rule.
But we also know that that is aseparate RFI.
So we would fully expect thatany feedback or determination
regarding that the deregulationaspect of the RFI likely will
come or can come in a separaterule, I would assume.
Speaker 1 (19:31):
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 havethis final rule and we're only
a few weeks from October 1, thestart of the fiscal year 2026?
Speaker 2 (19:47):
Yes, absolutely.
I mean certainly read the finalrule.
I think we say that every timeright, make sure that everyone
is clearly understanding whatthe changes are.
Certainly receive informationas we are imparting it, but also
your national associations andthe state associations are your
partners in making sure that youhave the information and
(20:09):
industry experts.
Absolutely looking atevaluating 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 havesaid.
I mean we can't underscoreenough the importance of
(20:31):
readiness related to hope, andthose 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 areneeded from a CHAP perspective,
and we will educate our own sitevisitors.
You know on what the changesare and what they are to be
(20:55):
looking for, but organizationsdo need to again evaluate their
own processes and policies toaffect these changes.
Speaker 1 (21:05):
You read my mind.
I was just going to saypolicies too, kim.
Right, absolutely All right.
So what we are hoping, inaddition to listening to this
podcast, that you would read thesummary we did put out about
the final rule and also you lookat anything from CMS that might
(21:27):
be available in the days tocome as they push things out
from the final rule, meaningthat there may be some
additional guidance on theregulatory text changes or on
the regulatory text changes or,who knows, even some more hope
tidbits as we're inching our waytowards that implementation
(21:48):
date.
Any final thoughts for us, kim?
Speaker 2 (21:50):
No, I think I believe that hospices are.
I'd like to believe thathospices are well on track.
You know certainly hope, Ithink, is the biggest challenge.
You know the regulatory changes, again operationally.
You know making sure that theyare ready for them, as well as
the financial impact of theeffect of the.
(22:11):
You know what the wage indexchanges are.
But I think that you know.
I feel very positive inspeaking with hospices about
their ability to be able toimplement, successfully
implement all of these finalrule requirements, likely with
(22:37):
some ongoing support andguidance and continued feedback
from the industry and from CMSregarding hope.
Speaker 1 (22:48):
Well, thank you so much, my good friend.
It's always a pleasure to talkquality and compliance with you,
for sure.
Speaker 2 (22:55):
Absolutely.
Speaker 1 (22:57):
Thank you, oh, you're welcome and thanks to all of
you, as usual, for taking timeout of your day to listen to our
podcast.
So, from Kim, me and the entireCHAP staff, keep your quality
needle moving forward, stay safeand well, and thanks for all
you do.
Thank you.
Greetings.
I'm Jennifer Kennedy, the Leadfor Compliance and Quality at
CHAP, and welcome to thissession of CHAPcast.
In today's session, we're goingto talk about the hospice
fiscal year 2026 final rule thatcame out at the beginning of
August of 2025.
(00:36):
And, of course, I have my goodfriend and colleague here to do
the chatting with me about allthings Hospice Final Rule Kim
Skian, and she is our VicePresident for Accreditation.
Hi Kim, how are you doing?
Speaker 2 (00:53):
Hi, jennifer, I'm doing really well.
I'm actually excited to talkthrough the Hospice final rule.
I was actually thinking aboutyou when I was reviewing and all
of your years of it's notperusing deep, diving with all
(01:14):
of the federal registers, allthe 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 alittle more comprehensive, if
you will, and easier than orless onerous.
I guess I would say yeah,that's it.
(01:38):
That's the word Less onerous.
Speaker 1 (01:40):
That's exactly it.
So when the proposed rule cameout earlier this year, I, you
know I always sweat to like, ohGod, what's going to be in it
and how many pages is it goingto be?
And 82 pages, that's nothing,right.
And I think you're right.
I think it was completely lessonerous than years past and I
(02:04):
think the, you know, the firstthing that we could start out
with is, in addition toproviding an overview of, you
know, the various provisions inthe rule.
But, kim, if you want to get usstarted about, you know some
good news, it's the paymentupdate.
Speaker 2 (02:23):
Yes, absolutely, and yep, I'm sorry, just as an
(02:52):
update.
Really, the best news, if youwill, from this with the payment
update is that there is anoverall 2.6% increase nationally
and the aggregate cap is$34,465.34.
It also is important to notethat your actual payment update
or payment change will be basedon your own MSA, your own I'm
sorry CBSA, to be able to makesure that you know that there
may be an adjustment up or down.
But overall, I would say thathospice at the moment and I'm
(03:14):
really going to knock on woodwhen I say this, you know is
faring overall much morepositively in terms of at least
having the opportunity to have arate increase.
Continue to have a rateincrease, given the environment.
Speaker 1 (03:32):
Yeah, I agree.
You know it is a fact that wecan look at that March MedPAC
report that comes out every yearfor Congress and you know, look
at that and it's usually thetiming is about a couple of
(03:55):
weeks before the proposedhospice rule posts.
But to get an idea of whatcould be coming in terms of
payment idea of what could becoming in terms of payment
either update or staying thesame or what have you.
But I'm very happy for hospiceproviders out there that it is a
2.6 bump in their rate.
(04:15):
We did have a couple ofregulatory text updates too, so
let's talk about those, kim.
Speaker 2 (04:23):
Sure.
Well, I think it's important tonote that the regulatory updates
that are published in the finalrule are not substantive in
terms of a regulatory languagechange and will not change the
intent of the regulation itself,just really further clarifies
and really supports increasingoverall or decreasing burden, I
(04:48):
guess I would say, for hospices.
So the first is the CMSfinalizing the proposal to add
the text or the physician memberof the hospice
interdisciplinary group tochanges that would include both
to the conditions of payment,the Medicare benefit policy
(05:11):
manual, and also we would makeregulatory or standards changes,
if you will, on the COP's side.
And this really was a win forhospices because this does align
again with the changes that arealready in the certification of
terminal illness paymentregulations and the medical
(05:36):
director COPs regs.
So we want to make sure thatthe message here is that CMS has
listened and clarified that notonly the physician member, not
just the medical director, theconfusion and the disconnect we
remember that from several yearsago Absolutely the disconnect
(05:57):
or difference betweendiscrepancy between the
conditions of payment and theconditions of participation,
between the conditions ofpayment and the conditions of
participation.
So any member, any physician,member of the hospice physician,
member of the hospiceinterdisciplinary group, not
(06:20):
just the medical director or thephysician designee can complete
the certification.
Speaker 1 (06:24):
So, kim, there's another one in terms of the
other text update, and what wegot on the final rule wasn't
what was proposed, and that'sactually a plus for providers as
well, don't you think?
Speaker 2 (06:40):
I do, and In this particular change, cms actually
did identify that the reason forthe change from the proposed
rule to the final rule was inresponse to comments.
(07:02):
We, you know, say anything elsethat this is another example of
the importance of providers andthe industry submitting comments
to any of the proposed rules,because you know there are
changes.
So, in this particular case,with the face-to-face
(07:25):
attestation, they originallycorrected an inadvertently
regulatory admission from the2012 hospice final rule to
restore the signature and daterequirements for the
face-to-face attestation.
And then the second part, whichis also this is the area that
was, or the section that was,finalized based on comments.
(07:50):
They finalized changes toreduce administrative burden by
eliminating the requirement thatthe attestation must be a
separate and distinct documentand then clarifying that the
attestation requirement may befulfilled.
Requirement may be fulfillednot only as either a clearly
(08:11):
titled section of an addendum tothe research, but also part of
a signed, dated clinical notewithin the clinical record.
So this is really important andprobably you know the area that
organizations hospices arereally going to need to look at
in terms of their own internalprocesses as well, as you know,
within their EMRs, to make surethat they can make these changes
(08:33):
, but ultimately this is a winfor hospice.
Speaker 1 (08:36):
Yeah, you know I agree with you.
One on the comments.
Comments can absolutely swayCMS and we've seen this.
You know the proposed wascompletely different than what
we got on the back end.
So no matter let's use the wordonerous today throughout this
(08:57):
podcast no matter how onerous itmay seem to put together a
comment letter, you know it canbe to everybody's benefit if
everybody weighs in and not onlysaying that you don't think
this is maybe a good idea, butproviding reasons for why it is
not a good idea and alternativesfor CMS to consider when you do
(09:22):
write that comment letter.
This is a complete win, I think, for providers for sure.
Speaker 2 (09:29):
Absolutely, Jennifer.
I know there were also updatesrelated to hospice quality
reporting and, of course, hope.
Do you want to?
Speaker 1 (09:40):
share some insight there.
Yeah, and again, I think thinkfor me everything was expected
and I know there were somerumors going around when the
proposed rule first posted andthen you know people that did
comment back, shared with methat they were asking for a
(10:03):
delay of the implementation.
But I didn't feel like CMS wasgoing to do that and they didn't
.
So we are on track for anOctober 1 implementation of the
HOPE assessment tool, which isjust a couple of weeks away.
(10:24):
So hopefully everybody is, youknow, being busy as bees in
order to be ready for thatimplementation.
Also, they did reiterate inthat quality area that the HOPE
quality measures, which are twoof them, would not be
implemented earlier than fiscalyear 2028, because they need to
(10:47):
really collect at least fourquarters of data, to look at
that data and analyze it to seeif it ticks all the boxes for
public reporting of thosemeasures.
And they'll keep us in the loopper the final rule about what
is happening with the dataanalysis and when they think
(11:11):
they will go ahead and startpublic reporting of those two
measures.
Also, they did state that theywould provide that communication
most likely in sub-regulatorychannels, versus waiting for the
(11:31):
next year's rule to communicatewhat they're doing with that,
and there might be something innext year's proposed rule, an
update or what have you, but Iwould expect sub-regulatory
communication to be it.
So that's why it's reallyimportant for providers to watch
that HQRP web page, in thespotlight page, particularly to
(11:53):
see when things are changing andupdated.
Now, the big thing here, kim, isthat the submission of HOPE
data is going to be via theI-KEY system.
The HIS submission is in theKEY system.
So it is extremely importantand I'm saying this as something
(12:22):
organizations have got to geton.
They've got to jump on this ifthey absolutely have not jumped
on it yet.
And actually the suggested datefor doing your application and
registering in iKeys was onSeptember 10th.
So if it's after September 10thand you're listening to this and
(12:44):
you haven't already establishedyour account, go there today,
as soon as you you're listeningto this and you haven't already
established your account, gothere today, as soon as you're
finished listening to thispodcast, and do your
registration in iKeys, becauseiKeys will stop accepting
records for HIS on the 30th ofSeptember and start accepting
(13:07):
HOPE on October 1 through I-Keys.
But it also was stated in thatfinal rule that any hospice
admissions and discharges thatoccurred prior to October 1,
including any corrections youhave, up until February 5th of
(13:27):
2026 if you have to makecorrections to those records.
So for me, reading that rule, Iwould say that was the big
enchilada.
For me in there was the hopecontent of the rule, absolutely.
Speaker 2 (13:42):
Yep, I just want to give a shameless plug for you,
jennifer, and for CHAP and forthe outstanding blog series that
you have put in, that youprepared and presented over the
past.
You know several episodes orseveral blog postings
specifically related to hopeimplementation.
(14:04):
So, along with any you know,cms education and any other
training that folks may receiveyour blog, jennifer's blog post
or the CHAP blog post thatseries is extremely important
and really provides somevaluable down-to-earth
information in terms ofimplementation.
(14:25):
Well, thanks, kim Sure.
Speaker 1 (14:28):
The only other thing, oh, one thing before we move on
.
We actually just posted ourlast pre-implementation blog, so
that is on our website now andwe developed a new what we're
calling a Hope Quick Tool thathas all of the important links
(14:48):
you need in one document.
Actually, it's not a document,it's right on our webpage.
So you just go to that tool andyou click and it takes you to
all the education and guidanceand manuals and tools that CMS
has put out regarding the HOPEtool, rather than you going to
(15:11):
separate web pages in CMS tosearch for all this stuff.
So that's up and availableright now.
Speaker 2 (15:17):
That's excellent and absolutely hospices should take
advantage, because there is somuch information flying around
and, frankly, we're under thegun and folks will continue to
have questions as hope isimplemented.
The one final thing I want toremind folks of is the fact that
, at least at this point in time, cms is implementing the 4%
(15:45):
reduction in hospice qualityreporting for the future, a
subsequent payment year if the90% compliance threshold for
submissions acceptablesubmissions is not met.
So there is no and, jennifer,I'm saying this so that you can
(16:05):
just validate this there is nodelay.
There is no, at this point intime, there is no delay in that
requirement.
So once the HIST, once weswitch over from HIST to HOPE,
that compliance threshold stillremains his to hope that
(16:26):
compliance threshold stillremains.
Speaker 1 (16:27):
Yep, it's still 90%, and that's an aggregated 90% of
accepted records.
So you can submit records tillthe cows come home, but if
they're not accepted, then youhave a problem when it comes
time for CMS to calculate yourcompliance.
So thanks, kim, for mentioningthat Nobody can take a 4% cut in
these days and times.
I think the last thing that wewant to talk about and I'm going
(16:52):
to throw the ball to you, kimis there were some requests for
information in that proposedrule and you know how did those
come out on the back end for thefinal rule.
Speaker 2 (17:06):
So, generally speaking, the advanced digital
quality measurement for thehospice quality reporting, as
well as the comments on thevariety of questions related to
the status of IT and technologyin hospice, along with input on
(17:27):
the importance, relevance,appropriateness and
applicability of the conceptsunder consideration, which
include interoperability,well-being and nutrition.
In those cases, there were nocomments or final rule or final
decisions that were provided inthe rule.
So what that means, at least atthis point, is that CMS in
(17:53):
those cases are holding on anyfurther action.
Jennifer, I just want to againjust have you clarify.
That does not mean that theycan't, in subsequent proposed
rules, add or basically considerthe comments or revisit these
(18:15):
particular RFIs.
Am I correct on that?
Speaker 1 (18:18):
Yeah, no that's absolutely right.
They absolutely can swingaround and I think definitely I
would expect them to swing backaround to the interoperability,
because that seems to be onething that is a huge focus up at
CMS, and it's not just forhospice, it's for everybody,
(18:40):
right.
So I would expect to see moreon that in future rulemaking.
Speaker 2 (18:45):
And I would say I would agree with that as well as
the deregulation request, rfiIn both of those cases there's
much more broad implications,not just for hospice but for all
CMS settings.
And specifically regarding thederegulation request, there was
no feedback or informationprovided in the hospice final
(19:08):
rule.
But we also know that that is aseparate RFI.
So we would fully expect thatany feedback or determination
regarding that the deregulationaspect of the RFI likely will
come or can come in a separaterule, I would assume.
Speaker 1 (19:31):
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 havethis final rule and we're only
a few weeks from October 1, thestart of the fiscal year 2026?
Speaker 2 (19:47):
Yes, absolutely.
I mean certainly read the finalrule.
I think we say that every timeright, make sure that everyone
is clearly understanding whatthe changes are.
Certainly receive informationas we are imparting it, but also
your national associations andthe state associations are your
partners in making sure that youhave the information and
(20:09):
industry experts.
Absolutely looking atevaluating 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 havesaid.
I mean we can't underscoreenough the importance of
(20:31):
readiness related to hope, andthose 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 areneeded from a CHAP perspective,
and we will educate our own sitevisitors.
You know on what the changesare and what they are to be
(20:55):
looking for, but organizationsdo need to again evaluate their
own processes and policies toaffect these changes.
Speaker 1 (21:05):
You read my mind.
I was just going to saypolicies too, kim.
Right, absolutely All right.
So what we are hoping, inaddition to listening to this
podcast, that you would read thesummary we did put out about
the final rule and also you lookat anything from CMS that might
(21:27):
be available in the days tocome as they push things out
from the final rule, meaningthat there may be some
additional guidance on theregulatory text changes or on
the regulatory text changes or,who knows, even some more hope
tidbits as we're inching our waytowards that implementation
(21:48):
date.
Any final thoughts for us, kim?
Speaker 2 (21:50):
No, I think I believe that hospices are.
I'd like to believe thathospices are well on track.
You know certainly hope, Ithink, is the biggest challenge.
You know the regulatory changes, again operationally.
You know making sure that theyare ready for them, as well as
the financial impact of theeffect of the.
(22:11):
You know what the wage indexchanges are.
But I think that you know.
I feel very positive inspeaking with hospices about
their ability to be able toimplement, successfully
implement all of these finalrule requirements, likely with
(22:37):
some ongoing support andguidance and continued feedback
from the industry and from CMSregarding hope.
Speaker 1 (22:48):
Well, thank you so much, my good friend.
It's always a pleasure to talkquality and compliance with you,
for sure.
Speaker 2 (22:55):
Absolutely.
Speaker 1 (22:57):
Thank you, oh, you're welcome and thanks to all of
you, as usual, for taking timeout of your day to listen to our
podcast.
So, from Kim, me and the entireCHAP staff, keep your quality
needle moving forward, stay safeand well, and thanks for all
you do.
Thank you.
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