Organizations including LeadingAge, the National Alliance for Care at Home and the National Coalition for Hospice and Palliative Care (NCHPC) are calling for CMS to develop a separate palliative care benefit, according to public comments submitted to CMS on Sept. 14, 2026. 
 
Comments were submitted in response to the CY 2027 Payment Policies Under the Medicare Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation proposed rule. 
 
“We ask CMS to do two things: create a distinct code that identifies specialty palliative care, and pay for it through a monthly bundle that sustains the non-billing members of the interdisciplinary team,” wrote Clarette Yen, vice president of legal affairs for LeadingAge, in the group’s comments. 
 
Both LeadingAge and the NCHPC noted palliative eligibility shouldn’t be based on prognosis or life expectancy instead of patient need. The Alliance recommended a two-factor eligibility framework focused on a life-limiting or serious diagnosis combined with demonstrated need, such as caregiver strain, hospital admissions or high symptom burdens. 
 
Commenters also stressed that palliative care should not be framed as a transition into hospice. 
 
To read LeadingAge’s comments, visit https://leadingage.org/wp-content/uploads/2026/09/LeadingAge-Comment-to-CY27-PFS-NPRM-09.14.2026.pdf. Other comments, including the Alliance’s and NCHPC’s, can be found at https://www.regulations.gov/document/CMS-2026-2377-0002.