Expert insights on compliance, surveys, billing, and running a successful hospice operation.
All three UPICs now run prepayment hospice reviews in rounds of ADRs, and CMS ties high SSVI scores to medical review. A practical readiness checklist.
CMS finalized the hospice SSVI for FY 2027. Learn the 9 measures, how the 0 to 16 score works, the thresholds, and steps to lower your risk.
Rates, LOC, visits, dx, and discharge change after the claim leaves. Waiting for an ICN creates a blind spot for billers.
CMS reissued Provider Preview Reports for the November 2026 Hospice Care Compare refresh in iQIES. The 30-day preview window runs August 25 to September 24, 2026; the files stay about 60 days total, then they are gone. Assessment/HIS Q1 2025–Q3 2025, CAHPS measures Q1 2024–Q4 2025, CAHPS Star Ratings Q4 2023–Q3 2025, claims-based Q1 2024–Q4 2025. Log in, download both the assessment/claims preview and the CAHPS preview, save them locally, and brief leadership on what families will see in November.
The May 13, 2026 nationwide hospice enrollment freeze runs six months under 42 CFR 424.570(b). The clock lands around November 13, 2026 — about nine weeks from today. CMS can extend it in six-month increments through the Federal Register, or lift it. What is still blocked (new 855A enrollment, new practice locations, non-exempt CIMOs, service-area expansions), what is not, and the operator list if the freeze is extended rather than lifted.
CMS-1851-F is final (91 FR 49118, effective October 1, 2026). Every Medicare hospice election on or after that date gets an Election Statement Addendum — not only on request — furnished within 5 days of the election effective date, with 3-day updates when the plan of care changes the relatedness call. Inside: what 42 CFR 418.24 actually finalized, a filled-in example using the CMS March 2024 model fields (and the stale “request” language you still have to rewrite), and how to put the patient-specific signed copy in an ADR packet so a reviewer can find it.
CMS-1851-F is law. 2.3% update or a 1.7% cut if you miss HQRP, mandatory election addendum on every Medicare admission, Compare icon coming, telehealth recert through 2027, and who can sign a discharge. The operator list for the next five weeks.
A new letter is landing at suspended California hospices: the “Response to Rebuttal Statement.” We reviewed two — dated July 27 and July 30, three days apart, nearly identical, both by FedEx: the rebuttal “was not sufficient to refute the credible allegation of fraud,” the suspension continues “pending additional investigation,” and the determination is not appealable (42 CFR 405.375(c)). Both redacted letters inside — including the passage where one agency’s own office address is cited as “statistically linked” to other providers’ suspensions and revocations. Why the denial was near-automatic no matter what the rebuttal said, why a denial arriving mid-way through your 30-day records-request window does NOT end the medical review, and the seven-step playbook for the phase that actually decides the case.
Idaho is one of the best SSVI states in America: 55 scored hospices, a median of 4 versus the national 6, zero hospices in the danger tail. This case study is about the exception — a real Idaho hospice (name, CCN, and city withheld) that scored a 9, the second-worst score in the state. Where the nine points actually come from: three utilization flags — one tripped by exactly one-tenth of a minute of nursing time, one clearable with a single GIP day, one 1.3 points from the line — on top of six spending points with just $12,400 of headroom before the score becomes a 10. What the hospice is NOT failing, the two watch items that could undo everything, and the two-fiscal-year arithmetic that brings a 9 back to state average.
Five states into this series, every post opened with a problem. This one opens with a congratulations. CMS scored 66 Oregon hospices on the FY2025 SSVI, and Oregon posts the best numbers in America among sizable states: an average of 4.2 of 16 versus 6.4 nationally, a median of 4 versus 6, and zero hospices in the 11+ danger tail. The stat of the series: not a single Oregon hospice tripped the long-stay flag or the live-discharge flag — nationally, a quarter of hospices trip each. The three disciplines behind the numbers (enrollment integrity, a nearly empty spending file at $1.04 per patient-day, visits that actually happen), the two structural reasons why (the oldest hospice market we’ve profiled — median first Medicare billing 2009 — and double the national nonprofit share), the one flag even Oregon trips, and the playbook operators in any state can copy.
CMS scored 82 Mississippi hospices on the FY2025 SSVI, and the state median is an 8 out of 16 — the worst state median in the nation, two full points above the national 6. Here’s the strange part: Mississippi is BETTER than the national rate on six of the eight care measures — its live-discharge flag rate is less than a third of the nation’s. The points are coming from the other half of the index: non-hospice spending, where 63% of the state sits in the top three national brackets, plus a weekend-visit flag rate tied with Texas for worst in America. The first state in our series that isn’t on CMS’s enhanced-oversight list — and it outscored all four states that are. The ten worst scores, the spending arithmetic, and a fix list that starts with next weekend’s schedule.
CMS scored 153 Nevada hospices on the FY2025 SSVI, and the state median is a 6 out of 16 — exactly the national median. So the typical Nevada hospice isn’t the story. This is: 68% of the state billed zero continuous home care and zero general inpatient days for the whole year, versus 45% nationally. It’s the fingerprint of a routine-home-care-only market that never escalates a patient to a higher level of care — paired with elevated live discharges and long stays. A distinct profile from Texas’s thin visits and California’s enrollment churn. Nevada is also the fourth of CMS’s four enhanced-oversight states, completing the cohort. The ten worst scores, what they share, what Nevada beats the nation on, and the fix list in order of effort.
Three months into the April 2026 Qlarant wave, outcomes are splitting: some hospices were lifted — we know agencies released without ever getting this letter — while at least some still-suspended providers are now receiving a Medical Review Records Request. We reviewed one, dated July 13: 30 claims across 19 patients — two of them carried over from the original five-chart rebuttal, now for different service months — chosen by Statistically Valid Random Sample, due in 30 days, with the sample’s denial rate extrapolatable across the entire claims universe. It arrives by Kiteworks, not certified mail — and the beneficiary list comes as a separate file. What the letter demands, the consequences ladder, and the first 72 hours.
CMS scored 2,002 California hospices on the FY2025 SSVI — nearly a third of the nation — and 173 of them scored 11 or higher out of 16, the largest danger-tail count in America, ahead of Texas’s 140. But the number that defines California is 55.9%: the share of the state tripping a live-discharge flag that CMS calibrated to catch the bottom quarter of the country. Half the state trips long stays too — while beating national rates on weekend visits, seven-day returns, and facility concentration. California’s problem isn’t service delivery; it’s who gets admitted and how long they stay. The mirror image of Texas, quantified per-CCN — and it lands in the most regulated hospice market in America.
CMS scored 998 Texas hospices on the FY2025 SSVI, and 140 of them — 14%, more than double the national rate — scored 11 or higher out of 16. That’s more hospices in the danger tail than 46 states have scored hospices at all. The state’s ten worst scores are a wall: every one is a 14, and every one also scored 11+ the year before — this is a stable operating pattern, not a bad year. Statewide, nearly half of all Texas hospices trip the skilled-nursing-minutes and weekend-visit flags — double the national rate. What the component data shows, what it doesn’t, and the fix list in order of effort.
CMS scored 221 Arizona hospices on the FY2025 SSVI, and 11.3% of them — roughly 1 in 9 — scored 11 or higher out of 16, a tier only 6.4% of hospices nationally reach. Only Texas puts a larger share of its hospices in the danger tail. But the pattern behind Arizona’s ten worst scores isn’t facility census or discharge churn — it’s long enrollments with thin visits: 9 of the 10 tripped skilled-nursing minutes, 9 of 10 tripped weekend visits, and 8 of 10 had patients dying without a skilled visit in the final two days. What the state’s component data shows, what it doesn’t, and the fix list in order of effort.
One sentence in Title 22 CCR § 74868(g) quietly rewires hospice care planning: your team may propose changes to the plan of care, but a modification “may only be implemented” once the attending physician, Medical Director, or Medical Director Designee “has approved the modification in writing.” The signature moved from the end of the story to the beginning — a verbal order no longer authorizes the change, and a surveyor can prove a violation with two timestamps. Who the three authorized signers are, why the initial plan has a stricter rule than modifications, the 2 a.m. on-call script that has to change, and the EMR question to ask this week.
A webinar guest asked whether their Designee at Hospice A can hold the fully titled position at Hospice B. The answer is no — and the reason catches almost everyone: the concurrent-employment bans in Title 22 CCR §§ 74876(f), 74852(e), and 74856(f) explicitly name the Administrator, DPCS, and Medical Director Designees, not just the titled officers. And the ban is written at the employment level, not the role level — a DPCS at Hospice A can’t even pick up on-call RN shifts at Hospice B. What the text says, what it doesn’t reach (home health, hospitals, SNFs are all fine), why the contract dodge fails for Medical Directors, and the same-rural-county exception, precisely.
Another webinar question: can the Administrator also serve as the DPCS — and does filling the Designee seats mean hiring somebody new? The text does not prohibit the dual role: California’s bans restrict serving multiple hospices, not holding multiple titles at one. But the person must independently clear both qualification bars (only a degreed RN with supervisory history can double up), both roles still need their own qualified Designee, and nobody can be their own backup. Why a Designee is an appointment in writing — not a mandatory new hire, and not necessarily full-time — the six leadership seats every hospice must fill, and the two 60-day vacancy clocks that start at once if your dual-role leader walks.
California’s new rules define the hospice interdisciplinary team at § 74800(a)(31) to include the patient’s family, the patient’s representative (that’s where a DPOA agent fits), and the caregiver — but each entry carries four load-bearing words: “if they so desire.” Participation is their right, not their obligation: you must welcome them onto the team if they want in, and a family that declines is not a compliance gap. Who the required members are, why the regulatory workload always stays with the “hospice employee members” under § 74864(b), and the one-sentence documentation habit that turns an unanswerable survey question into a documented choice.
California’s emergency hospice regulations (Title 22 CCR 74800–74908) have been live since June 22, 2026 — with no grandfather clause. So we built a 13-section, 100-plus-item Hospice Compliance Self-Audit Checklist mapped question by question to the regulation, where every box is a yes/no you should be able to answer “yes, and I can show you where.” The twist: each section routes its questions to the person who can actually answer them — your organization, your EMR vendor, or your field staff. What the 13 sections cover, the June 22 addendum item most agencies haven’t caught (recalculate your unmet-need math), the four fastest wins, and how to take the checklist home from our free weekly CDPH webinar — Wednesdays at 10:00 AM Pacific.
Title 22 CCR § 74860 spells out, for the first time in state law, what a hospice certification of terminal illness must contain: an individualized clinical narrative placed immediately above the signature that “must not contain check boxes or standard language used for all patients,” an attestation directly above the signature, and two signatures — Medical Director or Designee and the attending — each signed and dated. Plus a rule that catches good agencies: any addendum added to the narrative after signing has to be signed again, immediately following the addition. Most of it tracks federal 42 CFR 418.22 — but it is now a CDPH licensing deficiency a state surveyor reads line by line. What changed, where it bites, and the cert audit to run this week.
Title 22 CCR § 74856(f) limits a hospice Medical Director to “manage and be responsible for” only one hospice agency — and the same one-hospice cap independently binds your Administrator (§ 74876) and DPCS (§ 74852). There is no grandfather clause: it took effect June 22, 2026, so an MD serving two non-rural hospices is already out of compliance. What day the MD must be down to one, why CDPH does not pick which hospice keeps them (you do), how to have the conversation, the 60-day vacancy and 10-business-day CDPH-application clocks, and the 24 rural counties that qualify for the exception — which excludes every major-population county in the state.
Title 22 CCR § 74864 codifies the hospice assessment timeline you already run — RN initial assessment within 48 hours, interdisciplinary-team comprehensive assessment within 5 days, reassessment at least every 15 days — lifted almost verbatim from federal 42 CFR 418.54. So the honest question is what actually changed: not the deadlines, but the enforcer (a CDPH surveyor, with your license on the line), the odds of being tested, the reach (hospices Medicare never certified), and the burden of proof. Why “performed on time” and “charted on time” are two different clocks, why a visit date is the floor and not the finish line for proving the nurse was in the home, why the residence-and-safety note doubles as proof of presence, and the audit to run this week.
Running a hospice and a home health agency out of one office is one of the most ordinary arrangements in California home-based care — and Title 22 CCR § 74908 just made it a citable deficiency. The rule requires a hospice to occupy “unshared” office space it holds in “exclusive possession,” so same building is fine but same suite is not — and one owner, one Tax ID doesn’t change it, because “the licensee” means the hospice license. The exact § 74908 text, the aggregate CMS data showing at least 27 California suites are exposed right now, why CDPH wrote it this blunt, and the compliant sublease-and-signage fix that keeps you in the same building.
A webinar guest asked the sharper question: California’s new rules tie your Administrator (§ 74876), DPCS (§ 74852), and Medical Director (§ 74856) to a single hospice — but do they also bar that same person from serving a home health agency? The answer straight from the text: the concurrent-employment ban names “another hospice,” not home health — so the answer is yes, they can. Why CDPH plainly wrote it that way (home-health experience is even a listed qualification), the two rural exceptions, and the three things that still make a shared hospice/home-health leader risky even though it’s allowed — CDPH’s cross-entity “system reviews,” the on-premises duty, and the federal affiliations rule.
Title 22 CCR § 74868(h) — live since June 22 — requires any staff member or volunteer who observes a significant change in a patient’s condition to notify the attending physician, Medical Director, or designee “as soon as possible within 24 hours.” The exact text, why it’s an “or” (not the attending specifically), the four mandatory significant-change triggers, the written policies and timelines § 74868(i) forces you to have, the requirement in § 74892(q) that the notification live in the chart, and how it chains into written care-plan approval (§ 74868(g)) and the 15-day assessment (§ 74864(c)).
Title 22 CCR § 74848 — live since June 22 — sets the first hard nurse-caseload cap in U.S. hospice: a licensed nurse may be assigned no more than 12 patients at any one time. Why it’s a point-in-time ceiling and not an average, that RN and LVN both count, the RN/LVN skill mix that holds down cost under the cap (and the federal 15-day RN-assessment floor that bounds it), the 24/7 licensed-nursing requirement, the patient-acuity committee (half direct-care RNs, annual review, 30-day fixes), where CDPH got the number 12, and the caseload audit to run this week.
Title 22 CCR § 74820 makes every county in your service area pass an “unmet need” test — weighing likely hospice demand against the capacity of hospices already licensed there — before a new or expanded service area is approved. The exact corrected formula (cancer deaths × 5/3 vs. licensed hospices × 56), the June 22 CDPH addendum that fixed a real math error in it, a worked example, and what it means for expansion and change-of-ownership deals.
California’s new CDPH medical-record rules (Title 22 CCR 74800–74908) took effect this month — raising the bar on how you document medication administration and how you amend a visit note after it’s signed. Two new Hospice Engine features, already live in your system: a Medication Administration Record (MAR), and timestamped addendums that let a clinician or QAPI reviewer append to a visit note — each entry date/time stamped, the original preserved, printing at the bottom of the note. What changed, where to find it, and how to use it.
CDPH’s emergency regulations (Title 22 CCR 74800–74908, effective June 22, 2026) put hard degree and experience floors under your Administrator and Director of Patient Care Services — and there is no grandfather clause for those qualifications. The exact requirements for each role, why long tenure no longer protects a non-qualifying leader, and a step-by-step remediation plan for hospices whose current staff fall short — degree gaps, the DPCS experience pathway, the 60-day vacancy clock, and the credential file a surveyor will ask for.
On June 11, 2026, CDPH filed emergency regulations (Title 22 CCR 74800–74908) establishing California hospice’s first comprehensive licensing framework — intended effective June 22, live on OAL approval. The hard 12:1 nurse ratio, management qualifications and concurrent-employment caps, 120-day change-of-ownership rules, the 2-hour service-area standard, codified medical-record requirements, and a moratorium running into 2027 — broken down section by section, plus how it stacks on top of the federal Qlarant wave.
The first April 2026 Qlarant payment suspensions are lifting — and some hospices are finding out from a Medicare remittance, not a letter. We watched it happen to a California hospice: no notice from Qlarant, but a negative “L3” adjustment on the remittance reversed every withheld dollar — a $466,972.08 release. How to read the L3 sign convention, why the net check was smaller, and what to watch for on your own remittance advice.
A hospice that was clean on its own claims just had its Medicare enrollment revoked — because someone with managerial control had an undisclosed outside affiliation CMS deemed an “undue risk.” A redacted copy of the real letter, how the 2019 affiliations rule (42 CFR 424.535(a)(19) and 424.519) lets CMS revoke you for who you keep, the re-enrollment bar and Preclusion List that follow, and a six-step plan to vet your owners, managers, and medical director first.
On June 3, 2026, the FBI issued a public alert (I-060326-PSA) on emerging hospice fraud — door-to-door solicitation, free-service incentives, recruiter bonuses, enrollment without consent. For legitimate operators it’s a checklist of exactly what investigators are hunting for, arriving as CMS keeps ~800 LA hospices suspended. An eight-point self-audit of your intake, marketing, comp plans, and referral relationships.
Whether your login still says Kinnser or now reads WellSky, you don’t have to use it for billing just because you use it for charting. Hospice Engine bills your hospice — and home health, if you run it — directly from inside the application: daily NOE submission, eligibility checks, cap tracking, and flat $3-per-patient-per-day pricing. Our full process and pricing.
Use Consolo by WellSky for your hospice EMR? Your charting and your billing don’t have to come from the same place. Hospice Engine bills directly from within your Consolo application — no EMR change — with daily NOE submission, eligibility checks, claim validation, cap tracking, and flat $3-per-patient-per-day pricing. Here’s how it works.
Most billing companies won’t talk to you until you’re live on Medicare. We start during accreditation. Hospice Engine bills directly from your MatrixCare application — a flat $50/month while you’re getting set up (eligibility checks, Medicare timing, the test-patient readmit trap, cap guidance), then just $3 per patient per day once billing begins. Our full process and pricing for new MatrixCare hospices.
You don’t have to use HospiceMD for billing just because you use it for charting. Hospice Engine works inside your HospiceMD account as a third-party billing service — daily NOE submission, on-demand eligibility checks, cash-flow forecasting, and claim validation against your visit records. Our full process, and the pricing that usually comes in lower than billing through your EMR.
Looking up your score is the easy part. Knowing which flags to attack first — and in what order — is the hard part. How to read your component breakdown, why fixing all five flags at once is the wrong move, and what a 1-hour SSVI Action Plan session covers.
The avg skilled nursing minutes per RHC day flag catches 25% of hospices — and it’s one of the most correctable in the SSVI. How CMS calculates it from your claims (revenue code 055x, 15-min units, divided by every RHC day), why LPN visits count the same as RN visits, and the five operational changes that move the number.
The No CHC/GIP flag fires at nearly half of all scored hospices — almost twice the rate of any other utilization measure. Why it’s a fixed rule (not a percentile), how one unmanaged patient crisis cascades into three separate SSVI score hits, and what having an active GIP contract has to do with your live discharge and seven-day return flags.
The finale of our SSVI series. Your two 0–8 halves — non-hospice spending and utilization — add up to a 0–16 total, but the total alone tells you almost nothing. What a good or average SSVI score actually is (median ≈ 6), where all 6,600 hospices really land, and how to read your own breakdown to find the points that matter.
Our free SSVI Score Lookup just got an upgrade. Search your hospice and click one new link to see the point-by-point breakdown behind your score — which non-hospice spending bracket you landed in, and which of the eight utilization measures flagged you, each shown against that year’s exact CMS threshold.
The second half of the SSVI. The Utilization Score is up to 8 of the 16 points — but unlike non-hospice spending, it’s eight separate tripwires built from your own claims: levels of care, visit intensity, length of stay, and discharge patterns. The exact FY2025 thresholds for all eight measures, what each one tests, and how to bring the score down.
The first in our SSVI series. Non-hospice spending is up to 8 of the 16 SSVI points — the Part A/B and Part D dollars Medicare spends on your patients outside your per-diem. What counts, the exact FY2025 dollar thresholds, why CMS watches it, and six concrete ways to bring it down.
Hospices in the April 2026 Qlarant wave are getting an unannounced, in-person site visit around the time their payment suspension is lifted. The exact items the representative asks for — employee list, a photo of your software login, state license, medical supplies, business cards, census, and photos of your posted hours — plus how to be ready. Includes an example lift notice.
CMS calculated an SSVI score for nearly every U.S. hospice — then buried it in a spreadsheet. So we built a free lookup: search by hospice name or CCN to see your FY2024 and FY2025 Service and Spending Variation Index score, your component scores, and your national percentile.
Your rebuttal worked and the payment suspension was lifted. Now what? Here’s what actually happens with held funds, repayment plans, ongoing monitoring, and how to avoid getting flagged again.
The FY2027 proposed rule introduces the Service and Spending Variation Index — a 0-to-16 score built from nine claims-based measures that CMS has already calculated for every hospice. What it measures, how it feeds the enforcement wave, and why the June 1, 2026 comment deadline matters.
CMS's FY2027 proposed rule would require the Election Statement Addendum — the form listing what your hospice will not cover — at every election starting October 1, 2026, instead of only on request. The operational lift, the compliance trap, and how to get ready.
Hospices waiting on a Qlarant rebuttal decision want to know one thing: how long until Medicare payments restart? From what we are seeing across the April 2026 wave — about three weeks on average, with one agency cleared in just seven days.
A plain-English introduction to what Hospice Engine does — hospice EMR software, expert billing services, and PPEO consulting. Who we serve, how we are different, and how to get started.
On May 13, 2026, CMS imposed a six-month nationwide moratorium on new hospice and home health Medicare enrollments. Existing hospices keep operating — but the 36-month change-of-ownership rule just froze most M&A and new branches.
In three weeks, the LA-area hospice and HHA suspension count grew from 447 to roughly 800. The White House withheld $1.3 billion in California Medicaid. CMS Administrator Oz says he believes “at least half” of LA-area hospices are fraudulent. What changes for operators.
Fifteen business days is short. Extensions are being granted in under 24 hours when you ask the right way. Here is the email address, the three-sentence template, and a real example of an April 27 request that pushed the deadline to June 1.
The April 2026 Qlarant suspensions hit 447. The underlying CMS criterion (live discharge over 40% from Jan 2025 to Mar 2026) puts more than 1,200 California hospices in the flag zone — and LA County, with a median rate of 83.33%, is the bullseye.
Medicare is cracking down on hospices running Live Discharge rates over 40% between Jan 1, 2025 and Mar 31, 2026. Here is exactly where to click in Hospice Engine to see your number in under a minute.
In April 2026, a White House–led federal task force triggered one of the largest hospice enforcement actions in Medicare history. Here is what happened, where the authority came from, and the 15-day clock you're on if you got the letter.
A Qlarant Notice of Suspension is not an appeal. It is a 15-business-day, claim-by-claim documentation exercise that is explicitly not appealable. Here is the playbook that works.
CMS has used live discharge rates anywhere from the mid-50% range up to 100% to justify suspending 447 California hospices, with the audit window covering any rate over roughly 40%. Here is how the statistic works, what rates are actually normal, and how to audit your own hospice before you are flagged.
A payment suspension freezes hospice cash flow immediately, with no statutory right to emergency funds. The operational and financial survival playbook for California hospices under suspension.
The National Alliance for Care at Home is asking CMS to favor targeted tools like PPEO over the broad CRUSH fraud regulations. Here's what hospices should know.
Wondering how long it takes to switch to a third-party hospice billing service? Here's our step-by-step onboarding timeline — most agencies are fully transitioned in 2–3 weeks.
CMS has expanded its Provisional Period of Enhanced Oversight (PPEO) to Georgia and Ohio. With 22% of reviewed hospices losing their Medicare enrollment, learn how to prepare and survive PPEO.
Our PPEO Consulting service helps hospices prepare for and survive CMS's Provisional Period of Enhanced Oversight. With experienced consultants who understand what reviewers are looking for, we'll help you identify documentation gaps before they become enrollment-threatening problems.
PPEO Consulting: $300/hour
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