Hospice Wage Index, the Final Rule, and the Signals CMS Is Sending | Part One

The 2027 Hospice Final Rule is more than a reimbursement update—it’s a window into where Centers for Medicare & Medicaid Services (CMS) believes hospice care needs to go next.

In Part One, host Chris Comeaux sits down with hospice regulatory experts Annette Kiser and Judi Lund Person to look beyond the numbers and “read the tea leaves” in CMS’s latest rule.  They unpack what hospice leaders need to understand about the Hospice Election Statement Addendum, the growing scrutiny of unrelated services and non-hospice Medicare spending, telehealth reporting, and the Service and Spending Variation Index (SSVI).  As Judi explains, CMS’s commentary and responses to industry feedback can reveal as much about the agency’s direction as the regulations themselves.

The conversation also highlights why leaders should be paying close attention to the financial and compliance signals behind the rule.  Medicare Part A and B spending outside the hospice benefit increased significantly from 2020 to 2024, with more than $2 billion in non-hospice spending in 2024 and $510 million in patient cost sharing.  Meanwhile, CMS is using SSVI data to examine both hospice utilization and non-hospice spending—making it increasingly important for organizations to understand their metrics, investigate patient-level claims data, and approach these numbers as opportunities for quality improvement rather than simply compliance statistics. 

For hospice CEOs, finance managers and leadership teams, the message is clear: don’t wait for CMS’s signals to become enforcement problems.  Understand your data, prepare your teams, and start asking what your organization’s metrics are telling you now.

5 Key Takeaways

• The Hospice Election Statement Addendum requires immediate operational attention.  Beginning October 1, 2026, Medicare patients must receive the addendum within the first five days of electing the benefit, making clear ownership and implementation planning essential Today. 
• CMS is intensifying its focus on services billed outside the hospice benefit.  Reports involving equipment, supplies, wound care, oxygen, and common palliative medications reinforce CMS’s concern about whether hospices are covering services related to the terminal illness and related conditions. 
• SSVI deserves executive-level attention.  The Service and Spending Variation Index combines utilization and non-hospice spending measures, and leaders should understand not only their score but what is driving it. 
• Hospices need better visibility into patient-level non-hospice spending.  Judi recommends identifying sources of beneficiary-specific Part B claims information so organizations can determine who billed what, investigate questionable spending, and address problems at their source. 
• Telehealth reporting may be another CMS “tell.”  Beginning January 1, 2027, hospices will report a G-code when face-to-face visits are performed via telehealth, giving CMS greater visibility into utilization patterns and potentially raising questions when organizations rely heavily on virtual visits.
  
  

The Final Rule tells you what CMS is doing.  The details may tell you what CMS is preparing to do next.  Share this episode with your leadership, compliance, clinical, and quality teams, review your organization’s SSVI and non-hospice spending data, and start the conversations that need to happen now.

And this is only Part One. Don’t miss Part Two, coming this Friday, where Chris, Annette, and Judi continue the conversation about which hospices may be best positioned under the new rule—and where leaders should be paying particularly close attention. 

Show Transcript

Special Guest:

Annette Kiser

 Chief Compliance Officer with Teleios 

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Biography
 

 

 

 

 

Judi Lund Person 

Principal, Lund Person & Associates LLC

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Biography

 

 

 

 

 

 

Our Host

Chris Comeaux

MLAS, CPA
President / CEO of Teleios

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