FY 2027 Hospice Proposed Rule: What Leaders Need to Know
At Clover Consulting, we believe regulatory changes should never feel overwhelming—they should feel actionable.
CMS has released the FY 2027 Hospice Proposed Rule, and while many agencies will focus on the payment update, the real impact lies in compliance expectations, operational changes, and increased public transparency.
This is more than an update.
It is a shift in how hospices will be evaluated, monitored, and compared.
☘️ Key Takeaway #1: Payment Increases Come With Performance Expectations
CMS is proposing a 2.4% payment increase, but this comes with a critical condition:
Agencies that fail to meet quality reporting requirements will receive a -1.6% update instead.
That creates a 4% swing in reimbursement tied directly to compliance.
Clover Insight:
Revenue is no longer just volume-driven—it is compliance-driven.
☘️ Key Takeaway #2: CMS Is Focused on Non-Hospice Spending
CMS is raising significant concern about the rapid increase in non-hospice spending for hospice patients, which has grown from $790 million in 2020 to $2.07 billion in 2024.
This includes services and supplies that should often fall under the hospice benefit.
What this means for your agency:
- Increased scrutiny on related vs. unrelated determinations
- Greater expectation for care coordination
- Higher likelihood of audit if patterns appear inconsistent
Clover Insight:
If you are not monitoring non-hospice utilization now, CMS will be doing it for you—very soon.
☘️ Key Takeaway #3: Your Performance Will Be Public (SSVI Score)
CMS is introducing the Service & Spending Variation Index (SSVI)—a public score ranging from 0 to 16.
This score evaluates:
- Skilled visit utilization
- Length of stay trends
- Live discharge patterns
- Non-hospice spending
Higher scores indicate increased concern and potential for review.
Clover Insight:
This is your agency’s claims-based report card—and it will be visible.
☘️ Key Takeaway #4: Major Operational Changes Are Coming
Election Statement Addendum (Mandatory)
- Required for all admissions beginning October 1, 2026
- Must clearly define non-covered services and rationale
- Requires timely updates with plan of care changes
Expanded Discharge Authority
- Allows Medical Director, physician designee, or IDG physician to sign discharge orders
Telehealth Face-to-Face Changes
- Continued use—but with new restrictions and billing requirements
- Requires policy updates and staff education
Clover Insight:
These are not minor updates—they require workflow redesign and team alignment.
☘️ Key Takeaway #5: Quality Reporting Will Impact Reputation
CMS is proposing a public indicator on Care Compare for agencies that fail to meet quality reporting requirements.
Additionally:
- HOPE assessments must meet 90% on-time submission thresholds
- Public reporting of quality measures is expanding
Clover Insight:
Quality reporting is no longer behind the scenes—it is patient-facing and reputation-defining.
☘️ What Your Agency Should Be Doing Right Now
At Clover Consulting, we recommend immediate action in the following areas:
✔ Review your projected financial impact under the 2.4% update
✔ Audit your current quality reporting compliance (especially HOPE timeliness)
✔ Evaluate non-hospice spending patterns and related/unrelated determinations
✔ Prepare workflows for mandatory Election Statement Addendum implementation
✔ Review telehealth policies and ensure compliance with new restrictions
✔ Begin internal monitoring of metrics that will impact your future SSVI score
☘️ How Clover Consulting Supports Your Agency
We don’t just interpret regulations—we help you operationalize them.
Clover Consulting partners with agencies to:
✔ Identify documentation and compliance risks early
✔ Perform targeted audits aligned with CMS focus areas
✔ Provide clinician-specific education and feedback
✔ Monitor trends that impact both quality outcomes and reimbursement
✔ Support leadership with actionable, real-time insights
☘️ Final Thought
The FY 2027 Proposed Rule makes one thing clear:
CMS expectations are evolving.
Success will depend on your agency’s ability to:
- Understand the changes
- Implement them effectively
- Monitor performance continuously
Agencies that take a proactive, structured approach will not only remain compliant—they will outperform.
If your team would benefit from support navigating these changes, Clover Consulting is here to help. ☘️
