Snapshot
HCHB’s June 1, 2026 comment letter on the FY 2027 Hospice Proposed Rule supports CMS’s goals but argues that hospice policy should be more targeted, data-driven, and operationally realistic, especially around payment adequacy, program integrity, and beneficiary transparency. The letter says the proposed 2.4% payment update is directionally positive but still does not close the reimbursement-cost gap, points to declining use of higher-intensity levels of care like GIP and CHC as warning signs of access pressure rather than automatic fraud markers, and urges CMS to treat non-hospice spending oversight more carefully by using risk-adjusted, explainable, contestable measures instead of blunt aggregate thresholds. It also strongly opposes making the election statement addendum universal for every admission, arguing that this would create major administrative burden without solving the real transparency and billing coordination problems, and instead recommends targeted oversight, better external-provider accountability, clearer data access, and phased implementation for any new requirements.
