CMS Built a New Score That Flags Your Hospice for Oversight. Meet the SSVI — and You Have Until June 1 to Comment.

Buried in the FY2027 Hospice Wage Index proposed rule (CMS-1851-P) — issued April 2, 2026 and published in the Federal Register on April 6 — is a new tool that should have every operator's attention: the Service and Spending Variation Index (SSVI). It is a single 0-to-16 score, built from nine claims-based measures, and CMS has already calculated one for every Medicare-certified hospice in the country. Yours included. The comment window closes June 1, 2026.

If the last eighteen months taught operators anything — from the 447 California suspensions to the nationwide enrollment moratorium — it is that CMS now leads with data. The SSVI is the next step in that direction: a published, ranked score that tells CMS, and eventually the public, which hospices look like outliers. Here is what it actually measures, how it connects to the enforcement wave, and what you should do before the comment deadline.

What the SSVI Is

The SSVI is a transparency-and-oversight score. CMS describes it as a way to identify hospices whose service patterns and associated Medicare spending fall outside the norm. The index does not change your payment rate directly. What it does is give CMS — and, under the proposal, the public — a single number that summarizes how much of an outlier your hospice looks like on claims data.

Critically, CMS did not just propose the concept. It released a methodology document and an individual SSVI score for every hospice alongside the proposed rule. This is not a future program waiting on a final rule to generate numbers. The numbers already exist. The rulemaking is about how CMS formally uses and publishes them.

How It's Scored: 0 to 16, From Nine Claims-Based Measures

The mechanics, as proposed:

• The index is built from nine claims-based measures, each capturing a different aspect of hospice utilization and the Medicare spending that surrounds your patients.
• Each hospice receives a composite score on a scale where 0 is the lowest (least concerning) and 16 is the maximum (most concerning).
• Scores are calculated from FY2024 and FY2025 claims and utilization data — meaning the behavior being scored has already happened. You cannot change your FY2027 score by changing how you operate today; you can only change where you land the next time the window rolls forward.
• A higher score signals to CMS potentially concerning utilization patterns and non-hospice spending, and is intended to prompt targeted education or increased oversight.

One honest caveat: the public summaries of the rule confirm the nine-measure structure and the 0-to-16 range, but CMS's full measure-by-measure specification lives in the rule text and the accompanying methodology file. If your score looks high, the methodology document is where you go to see which specific measures drove it. We can help you pull and read it — see below.

The Real Signal: It's About Non-Hospice Spending

The most important thing to understand about the SSVI is what it is really watching: Medicare spending on your patients for services the hospice itself does not cover. Think Part B and Part D claims — the office visits, the drugs, the procedures that get billed outside the per-diem while a patient is on your census.

Why does CMS care? Because a high volume of non-hospice spending on enrolled patients is one of the cleanest statistical signatures of two problems CMS is hunting:

• Patients who may not be appropriately certified as terminal — if a patient is still actively pursuing curative care billed to Part B, that is a relatedness and eligibility question.
• Costs being shifted off the hospice benefit — when items and services that should be covered under the per-diem (because they relate to the terminal prognosis) get billed elsewhere, Medicare pays twice.

This is the same logic that makes your live discharge rate such a powerful flag. Both are claims-derived numbers that, when they sit far from the norm, invite a closer look. The SSVI just packages several of those signals into one ranked score.

How This Connects to the Enforcement Wave

It is no accident that the SSVI arrived in the same season as the suspensions and the moratorium. CMS itself frames the index as part of its broader fraud, waste, and abuse prevention work. Lined up, the pieces form a single enforcement architecture:

• The Qlarant suspensions — now closer to 800 in the LA area — cut off cash flow to providers CMS already suspects of fraud.
• The six-month national enrollment moratorium freezes the inflow of new providers while CMS sharpens its analytics.
• The SSVI gives CMS a standing, refreshable ranking of the existing population — a way to decide who gets the next letter, the next ADR, the next site visit.

In other words: the suspensions are the enforcement, and the SSVI is part of the targeting engine that feeds it. If you operate in a PPEO state or anywhere the analytics are already running hot, your SSVI score is a preview of how the next pass is likely to rank you.

Wait — Didn't CMS Already Try a Targeting Program?

Yes. The Hospice Special Focus Program (SFP), finalized for 2025, was supposed to publish a list of poor-performing hospices for intensified oversight. CMS released an initial list of 50 hospices, several state associations sued, and in February 2025 CMS ceased implementation to "further evaluate the program." It remains paused.

The SSVI is not the SFP, and CMS has not said it is a replacement. But the through-line is unmistakable: CMS wants a defensible, data-driven way to rank hospices and direct oversight at the outliers. The SFP tried to do it through a quality-and-complaint algorithm and got tangled in litigation over methodology. The SSVI does it through claims-based spending and utilization data — the kind of data that is harder to argue with and that CMS has used successfully to justify the suspension wave. Operators who assumed the SFP's pause meant the targeting effort died should read the SSVI as evidence that it simply changed form.

Also in the FY2027 Proposed Rule

The SSVI is the headline, but it is not the only thing operators need to track in CMS-1851-P:

• A 2.4% payment update — roughly $785 million more in aggregate hospice payments versus FY2026, from a 3.2% market basket reduced by a 0.8-point productivity adjustment. The effect is uneven: rural hospices see roughly 3.0% and urban hospices roughly 2.3%.
• A new aggregate cap of $36,210.11 for FY2027. If you run long lengths of stay, model your cap exposure against this number now — cap liability is itself one of the patterns CMS analytics watch.
• A mandatory Election Statement Addendum. CMS proposes requiring the addendum — the form that spells out what the hospice will not cover — for every Medicare beneficiary at the time of election, for elections on or after October 1, 2026, instead of only on request. We break that down in its own post: the addendum becomes mandatory. It is the operational companion to the SSVI — the addendum is partly CMS's answer to the same non-hospice-spending problem the SSVI measures.

What Operators Should Do Before June 1

1. Find your SSVI score. CMS released a score for every hospice with the proposed rule materials. Look yours up in seconds here, then pull the methodology document. You want to know your number before anyone else uses it to make a decision about you.
2. If your score is high, find out why. The score is a composite; the methodology file is where you see which measures drove it. High non-hospice Part B/Part D spending on your enrolled patients is the usual culprit — and it is often a relatedness-determination and documentation problem, not a fraud problem. But you have to be able to explain it.
3. Audit your relatedness determinations. Every service billed outside your per-diem for an enrolled patient should have a documented determination that it is unrelated to the terminal prognosis. If those determinations are thin, that is exactly the gap the SSVI surfaces.
4. Submit a comment by June 1, 2026. This is a proposed rule, not final. The methodology, the public-reporting plan, and the measure selection are all still open for comment. The trade associations are engaging; individual operators can too. If the index mis-scores a legitimate care pattern common to your population, the comment period is the moment to say so on the record.
5. Assume publication. CMS's clear direction is toward public transparency on hospice outliers. Plan as though your SSVI score will eventually be visible to referral sources, payers, and the press — and get your number defensible before it is.

Further Reading

• The Election Statement Addendum Becomes Mandatory: What the FY2027 Rule Means for Every Admission
• CMS Froze New Hospice Enrollments Nationwide — What the 6-Month Moratorium Means
• CMS Pauses Medicare Payments for 447 California Hospices: What the Qlarant Letter Means
• The Live Discharge Rate Trap: How to Check Yours Before You're Next
• Who Is Next? The 1,200 California Hospices in the Flag Zone
• CMS Fact Sheet — FY2027 Hospice Wage Index Proposed Rule (CMS-1851-P)
• Federal Register — FY2027 Hospice Proposed Rule (comment by June 1, 2026)

The Bottom Line

The SSVI turns the enforcement era's data-first approach into a standing score that already sits next to your hospice's name. It does not move your rate, but it shapes who CMS looks at next, and it is pointed squarely at non-hospice spending and utilization outliers. The rule is still proposed, the comment window closes June 1, and the smartest move this week is the same one we have recommended through every story this year: see what CMS sees about your hospice — before they act on it.