Medicare Hospice Changes for 2027: What Leaders Need to Address Before Year-End

The Mandatory Election Addendum Is an Immediate Operational Requirement

Beginning with hospice elections effective October 1, 2026, hospices must provide every Medicare beneficiary, or the beneficiary's representative, with a written hospice election statement addendum. Previously, the addendum generally had to be furnished when requested. Under the FY 2027 final rule, it is mandatory for all hospice elections beginning on or after October 1, 2026.

The addendum identifies conditions, items, services and drugs the hospice has determined are unrelated to the terminal illness and related conditions and therefore are not covered under the hospice benefit.

It must generally be furnished within five calendar days of the effective date of the hospice election.

The process cannot stop there.

When a change to the patient's plan of care affects information contained in the addendum, the hospice must furnish an updated addendum within three calendar days of that plan-of-care change.

A beneficiary's signature acknowledges receipt of the document. It does not mean the beneficiary agrees with the hospice's coverage determination.

Hospices should also ensure that patients and representatives understand their right to seek assistance or appeal a disagreement regarding the hospice's determination through the Beneficiary and Family-Centered Care Quality Improvement Organization, or BFCC-QIO.

Enforcement Discretion Does Not Delay the Requirement

CMS has established an enforcement-discretion period from October 1 through December 31, 2026 as hospices transition to the mandatory addendum process. During this period, Medicare Administrative Contractors will focus on education and will not deny claims solely because the addendum is missing or incomplete.

That should not be interpreted as a postponed effective date.

The requirement took effect October 1. Hospices should therefore implement the process now and use the enforcement-discretion period to identify and correct workflow problems.

Leadership should be able to answer:

• How is every new hospice election triggering the addendum process?
• Who makes and documents the related-versus-unrelated determination?
• Who prepares and furnishes the addendum?
• How are the five-day and three-day requirements monitored?
• How are beneficiary questions and disagreements escalated?
• How does the process work during weekends, holidays and staff absences?

A useful early compliance review is to examine the first group of October elections for missed addenda, late updates, incomplete documentation and unresolved questions.

FY 2027 Payment Planning Should Use the Corrected CMS Files

CMS finalized a 2.3% FY 2027 hospice payment update. The finalized FY 2027 hospice aggregate cap is $36,174.75.

Hospices that do not satisfy applicable Hospice Quality Reporting Program requirements remain subject to the existing four-percentage-point reduction in their annual payment update.

For FY 2027, applying that existing reduction to the 2.3% update results in a 1.7% reduction from the previous year's payment rate. This four-percentage-point HQRP reduction is not a newly created FY 2027 penalty. CMS finalized the higher four-point reduction beginning with the FY 2024 annual payment update.

Finance teams should avoid treating the national 2.3% update as an automatic 2.3% increase in organizational revenue.

Actual financial performance will still depend on factors including geographic wage adjustments, service mix, cap position and HQRP compliance.

Use the Corrected FY 2027 Wage-Index and Payment Information

CMS identified a technical error affecting the original FY 2027 hospice wage-index information and subsequently issued a correction notice and updated FY 2027 wage-index and payment files.

The corrected FY 2027 wage-index file was posted September 29, 2026.

That changes the operational recommendation.

Finance and billing teams should no longer simply check whether a correction may be needed. They should confirm that their systems, rate tables and forecasts are using the corrected FY 2027 CMS files.

The Discharge-Order Change Expands Who May Authorize the Order

Effective October 1, 2026, Medicare's hospice payment regulations permit the written discharge order to be provided by:

• the hospice medical director;
• a physician designee; or
• a physician member of the hospice interdisciplinary group.

The previous payment regulation specifically identified the hospice medical director.

CMS describes this as a conforming regulatory change that improves flexibility and aligns the payment regulation with existing hospice requirements.

For hospice leaders, the practical issue is whether internal processes reflect that flexibility.

Policies, physician responsibilities, escalation procedures and EMR permissions should be reviewed together. An organization may technically have additional authorized physicians but still experience avoidable delays if its internal workflow continues to route every discharge order to one individual.

January Telehealth Reporting Requires Both an Eligibility Check and a Claims Workflow

Beginning January 1, 2027, hospices must report qualifying face-to-face recertification encounters performed through telecommunications technology using HCPCS code G0679.

CMS instructions call for reporting the encounter on a separately dated line using hospice bill types 81x or 82x and revenue code 0657. The encounter continues to be treated as an administrative expense.

CMS's contractor implementation date is January 4, 2027.

The current guidance is contained in CMS Transmittal 13944, R13944CP, issued September 2, 2026. That transmittal replaced the earlier July instructions.

Hospices should verify that billing-system configuration, internal job aids and vendor guidance reflect the September instructions rather than an older version.

Reporting Permission and Telehealth Eligibility are Different Questions

The availability of telehealth for qualifying hospice recertification face-to-face encounters continues through December 31, 2027, subject to statutory restrictions.

Those restrictions can involve circumstances associated with enhanced oversight, enrollment moratorium provisions and practitioners who are neither Medicare-enrolled nor qualifying opt-out practitioners.

The reporting requirement beginning January 1 does not remove those underlying eligibility checks.

The nationwide hospice enrollment moratorium should also be interpreted carefully. CMS's 2026 nationwide moratorium applies to initial Medicare enrollment applications, including certain non-exempt changes in majority ownership. It does not, by itself, eliminate the telehealth recertification flexibility available to hospices that are already enrolled in Medicare.

Operationally, that means hospices need two controls:

1. Telehealth eligibility: Was the practitioner and encounter eligible to use telecommunications technology?
2. Claims reporting: Was the qualifying telehealth encounter accurately carried from clinical documentation into the claim?

A billing code cannot substitute for the first determination.

Before January, leadership should request end-to-end testing that follows a sample telehealth encounter from clinical documentation through claim generation. The test should also include a case where the encounter method or practitioner status is unclear, so staff demonstrate how clarification is obtained rather than inferred.

HOPE Requires Attention to Submission Success, Not Just Assessment Completion

The Hospice Outcomes and Patient Evaluation, or HOPE, was implemented October 1, 2025 and replaced the Hospice Item Set. Hospice quality reporting has therefore already moved into the HOPE environment. This is an ongoing responsibility, not a January 2027 implementation.

Required HOPE records must be submitted through iQIES, and CMS requires applicable HOPE records to be submitted within 30 days of the relevant HOPE admission, HOPE Update Visit or discharge date.

The distinction between completing a HOPE assessment and successfully reporting it matters.

A record may be complete inside the EMR but still require:

• successful submission to iQIES;
• confirmation that the submission was accepted;
• monitoring for rejected records or validation issues;
• correction of identified errors; and
• confirmation that corrected information was successfully received.

Leadership reporting should therefore show more than “assessment completed.”

Quality teams should reconcile expected records against accepted iQIES submissions and track unresolved errors and corrections. CMS also encourages providers to monitor their iQIES quality-measure reports and make corrections before applicable public-reporting correction deadlines rather than waiting until those deadlines approach.

HOPE Public Reporting and Future HOPE Measures Should Be Kept Separate

There are two related but different developments that should not be collapsed into one statement.

First, HOPE data are entering the hospice public-reporting framework beginning in 2027.

Second, CMS has finalized two new HOPE-based quality measures:

• Timely Follow-up for Pain Impact; and
• Timely Follow-up for Non-Pain Symptom Impact.

Public reporting of these new HOPE-based measures is anticipated no earlier than November 2027, subject to CMS's assessment of data quality and reportability. Hospice leaders should therefore think of 2027 as the year in which today's HOPE submission discipline increasingly becomes tomorrow's public-facing quality information.

The Future Care Compare Icon Raises the Visibility of Reporting Compliance

CMS also finalized a future Medicare.gov Compare tool icon related to insufficient quality-data reporting. The icon will identify hospices that fail to submit quality data or submit less than the required 90% of quality data within the applicable period.

CMS states that implementation will occur no earlier than FY 2028.

The icon should not be confused with a comprehensive clinical-quality score. It communicates information about quality-data reporting compliance.

That distinction is important because a reporting-compliance indicator and an assessment of care quality answer different questions. For leadership, however, both carry reputational consequences. Missing or unsuccessful HOPE submissions can ultimately become visible outside the organization.

SSVI Should Be Treated as an Oversight Signal, Not a Finding of Inappropriate Care

CMS's Service and Spending Variation Index, or SSVI, uses nine claims-based measures to examine patterns in hospice utilization and non-hospice spending during hospice elections.

CMS uses the SSVI to help identify providers that may warrant additional transparency, education or oversight.

An SSVI result should not, by itself, be interpreted as a finding that a hospice provided inappropriate care.

It is better understood as an oversight and transparency signal that may identify patterns warranting further review.

Hospice leaders can use the same logic internally.

Where spending or utilization patterns appear unusual, clinical and financial teams should review underlying records and ask whether the pattern reflects documentation, coordination, coverage determinations, communication with outside providers or another explainable circumstance. The election statement addendum creates an additional connection. When the hospice determines that an item or service is unrelated to the terminal illness and related conditions, the organization should be able to locate and explain the clinical basis for that determination.

Aggregate data can indicate where to look. The individual patient record remains essential to understanding what actually occurred.

A Year-End Leadership Agenda

Rather than creating one broad “2027 readiness” project, hospice organizations can divide the work according to urgency.

Priorities for Immediate Action

Prioritize the requirements already in effect:

• Verify the mandatory election-addendum workflow.
• Confirm five-day delivery and three-day update controls.
• Educate staff regarding beneficiary BFCC-QIO rights.
• Use the CMS enforcement-discretion period to find and correct implementation problems rather than postponing implementation.
• Update discharge-order policies and EMR permissions.
• Confirm finance and billing systems use the corrected FY 2027 wage-index and payment files.

Test During October and November

Prepare for January telehealth reporting:

• Confirm implementation of CMS Transmittal 13944.
• Validate G0679 claim configuration.
• Test the path from encounter documentation to claim generation.
• Review practitioner eligibility and applicable telehealth restrictions.
• Include contracted practitioners and ambiguous documentation in testing scenarios.

Maintain Oversight Through Year-End and 2027

Strengthen ongoing quality-reporting controls:

• Reconcile required HOPE records against iQIES submissions.
• Monitor acceptance, rejection, and correction activity.
• Track the 30-day submission requirement.
• Review iQIES reports and applicable correction deadlines.
• Prepare leadership for the increasing public visibility of HOPE data.
• Monitor future CMS implementation of the HOPE-based quality measures and Care Compare reporting icon.
• Review SSVI and other utilization information as oversight signals requiring context rather than automatic conclusions.

The goal is not simply to maintain a list of regulatory changes. It is to connect every requirement to an owner, a workflow, a control and evidence that the process is functioning.

Addressing Operational Gaps with the Right Support

Cliniqon provides hospice coding and clinical quality-assurance support, including ICD-10-CM coding, plan-of-care review, concurrent clinical documentation review, review of records supporting hospice eligibility and related hospice documentation services. Cliniqon's hospice services also include IDT-related support.

Organizations evaluating outside support should define which activities remain the responsibility of hospice clinicians, which activities the external partner will review and how identified documentation or coding questions will reach resolution.

Preparing your hospice for the coming changes? Speak with Cliniqon about your coding and QA priorities, the documentation gaps your team is managing and where additional review support could help.