WASHINGTON, D.C. — The National Partnership for Healthcare and Hospice Innovation (NPHI), the national voice for nonprofit hospice and advanced illness care, has submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) regarding the Fiscal Year (FY) 2027 Hospice Wage Index and Payment Rate Update, Hospice Conditions of Participation Updates, and Hospice Quality Reporting Program Requirements proposed rule.
In the letter, NPHI welcomed CMS’s continued engagement with hospice stakeholders and offered detailed recommendations designed to strengthen patient access, improve transparency, reduce unnecessary administrative burden, and support high-quality, community-based hospice and palliative care.
“As hospice care continues to evolve, it is essential that federal policy supports both patient access and high-quality care,” said Tom Koutsoumpas, Founder and CEO of NPHI. “Our comments encourage CMS to pursue policies that are practical and informed by the realities providers face every day while caring for patients and families with advanced illness. We appreciate the agency’s continued engagement with stakeholders as it considers these important issues.”
While CMS proposed a 2.4 percent hospice payment update for FY 2027, NPHI emphasized that many nonprofit hospice providers continue to operate on exceptionally narrow margins while caring for a disproportionate share of patients with complex medical and social needs. NPHI encouraged CMS to pursue future payment reforms that better align reimbursement with patient acuity and resource utilization.
A significant portion of NPHI’s comments focused on CMS’s proposed non-hospice spending measures and the new Service and Spending Variation Index (SSVI). NPHI expressed concern that the proposal would hold hospices accountable for categories of Medicare spending over which they have little to no clinical, operational, or financial control.
NPHI urged CMS to provide hospices with access to patient-specific claims information, improve coordination across Medicare Parts A, B, and D, and delay implementation of non-hospice spending measures until providers have the tools necessary to evaluate and respond to the underlying drivers of spending.
The letter also provided detailed feedback on the proposed SSVI utilization measures. While NPHI strongly supports targeted program integrity efforts that identify and address fraudulent or abusive providers, the organization encouraged CMS to refine several measures to better account for patient choice, local market dynamics, facility-based care needs, and the individualized nature of hospice care.
In addition, NPHI raised concerns regarding proposals that would require hospices to provide the Election Statement Addendum to all patients. While supporting efforts to improve patient understanding and transparency, NPHI noted that the proposal would create significant operational burden while providing limited additional value to many patients and families.
“NPHI supports thoughtful program integrity solutions that protect beneficiaries and taxpayer dollars,” Koutsoumpas said. “However, new requirements should be carefully evaluated to ensure they meaningfully benefit patients and do not unnecessarily divert resources away from direct patient care.”
The proposed rule also included several Requests for Information (RFIs) on future hospice and serious illness care policy. NPHI provided extensive feedback on non-hospice spending, hospice quality measurement, the development of a hospice-specific wage index, community-based palliative care, and stakeholder perspectives regarding Medical Aid in Dying (MAID).
Notably, NPHI expressed strong support for the administration’s efforts to explore expanded access to community-based palliative care and commended CMS for seeking stakeholder input on ways to better serve individuals living with serious illness before they become eligible for hospice care. NPHI is currently developing a community-based palliative care model and welcomed CMS’s interest in advancing this important area of care.
Throughout its comments, NPHI emphasized the importance of policies that support patient access, preserve provider sustainability, reduce administrative complexity, and recognize the unique role nonprofit hospice providers play in caring for patients and families nationwide.
NPHI will continue engaging with CMS, the Administration, and Congress as the agency reviews stakeholder feedback and moves toward publication of the FY 2027 Hospice Final Rule later this year.
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