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HCANYS Comments on CMS’ FY 2026 Hospice Proposed Rule

The Situation Report | June 23, 2025

In comments to the U.S. Centers for Medicare and Medicaid Services (CMS), HCANYS focused on the following areas of the proposed hospice rule for fiscal year (FY) 2026.

These include:

  • Inadequacy of the proposed 2.4% FY 2026 Hospice Payment Update;
  • Inequities of the FY 2026 Hospice Wage Index Update;
  • Regulatory revisions to the Face-to-Face (F2F) Encounter Attestation Requirements;
  • Issues with the Hospice Outcomes & Patient Evaluation (HOPE) Tool; and,
  • Request for Information (RFI) on Advance Digital Quality Measurement (dQM) in the Hospice Quality Reporting Program (HQRP).

In the comments, HCANYS Vice President for Finance and Management Patrick Conole writes that the proposed 2.4 percent hospice payment update is inadequate and should be revised by Congress when considering the following new factors:

  • Severe workforce shortages caused by caregiver burnout and other reasons;
  • Increased costs related to management fees, outsourcing, recruitment, staff retention; and
  • Raising prices and other inflationary pressures such as the increased costs for supplies, drugs, personal protective equipment (PPE) and other items essential to the delivery of high-quality hospice care.

Mr. Conole also reasserts HCANYS' request for “wholesale revision and reform” of the pre-floor, pre-reclassified wage index which is “wholly inadequate for adjusting hospice and home health costs.”

CMS also finalized two years ago a 5-percent cap on losses in wage index values — a safeguard that should be strengthened and lowered to 2 or 3percent in order to ease the impact of wage index revisions and “protect hospice providers who are already operating with negative or razor-thin operating margins,” we write.

HCANYS expects CMS to issue the FY 2026 Hospice final rule in late July or early August; HCANYS will provide the membership with a detailed analysis of that rule.