Alliance asks CMS to proceed with caution for looming regulatory changes

Some hospice stakeholders are calling for CMS to approach new regulatory requirements finalized in the 2027 hospice proposed rule with “enforcement discretion.” That’s language used in a letter from the Alliance for Care at Home, published on Sept. 10. 

 

Starting Oct. 1, hospice providers will be required to supply all patients with a version of the hospice election statement addendum, which details which services hospice won’t cover. The form must be provided within five days of hospice election. Agencies must also create an updated version of the document within three days of any relevant changes made to the plan of care. 

 

The short timeframe is a key concern, wrote Katie Wehri, vice president of regulatory affairs, quality and compliance for the National Alliance for Care at Home, in the Alliance’s letter. She also noted that many providers have been confused by language calling for agencies to supply a “written” addendum, which has created some questions around whether electronic copies will be acceptable. 

 

CMS received similar requests when rolling out the Hospice Outcomes and Patient Evaluation (HOPE) tool in October 2025. Organizations such as LeadingAge and the National Alliance for Care at Home submitted requests that CMS waive its HOPE timeliness submission requirement until two calendar quarters after the tool's implementation. 

 

To view the Alliance’s letter, visit https://allianceforcareathome.org/wp-content/uploads/2026.09.10_Alliance-Election-Stmt-Addendum_Enforcement-Discretion.pdf.