Non-Compliance Notifications & HOPE Training

CMS

by Kristin Rowan, Editor

Hospice Non-Compliance Notifications

On July 21, 2025, the CMS Hospice QRP Announcements page added an update titled “Hospice Quality Reporting Program: Non-Compliance Notifications.”

The Update Reads:

The Centers for Medicare & Medicaid Services (CMS) is providing notifications to hospices that were determined to be out of compliance with Hospice Quality Reporting Program (HQRP) requirements for calendar year (CY) 2024…. This will affect their fiscal year (FY) 2026 Annual Payment Update (APU). The Medicare Administrative Contractors (MACs) will distribute Non-compliance notifications and place them into hospices’ Certification and Survey Enhanced Reporting (CASPER) folders in QIES on July 21, 2025. Hospices that receive a letter of non-compliance may submit a request for reconsideration to CMS via email no later than 11:59 pm, August 26, 2025. If you receive a notice of non-compliance and would like to request a reconsideration, see the instructions in your notification and on the Reconsideration Requests webpage.

Details

Any reconsiderations containing protected health information (PHI) will not be processed. All PHI must be removed for a reconsideration to be reviewed.

Additionally, all submissions must be less than 20 MB overall (email message and attachments). Submissions that are greater than 20 MB in size cannot be processed.

HOPE Training

As the implementation date for the HOPE tool drew nearer, advocacy groups and hospice agencies expressed concern over it’s readiness. On June 6, 2025, The Rowan Report shared that three of the largest organizations urged CMS to delay the tool. The groups asked for proper information, education, and training. 

CMS Response

As of now, CMS is not delaying the implementation of the HOPE tool. They have, however, published training tools for hospice providers. The first series of videos is Didactic Training. They cover an introduction to the tool, admin information, preferences and active diagnoses, health conditions, skin conditions, and medications.

On July 21, 2025, CMS announced the opening of registration for live HOPE training. “Hospice Outcomes and Patient Evaluation (HOPE) National Implementation Virtual Training Program Course 2: Coding Workshop.” CMS recommends completing The Didactic Training as a prerequisite to the Coding Workshop.

The Centers for Medicare & Medicaid Services (CMS) is offering a live coding workshop on August 5, 2025…. It will provide coding practice for items that are new for HOPE, as well as the existing and updated items carried over from the Hospice Item Set (HIS).

Register now at:The Hospice Outcomes and Patient Evaluation (HOPE) National Implementation Coding Workshop

Find the Didactic Recorded Training Series here.

Data Collection Starts Soon

The HOPE tool begins data collection on October 1, 2025. Key items hospice providers should understand:

  • More Frequent Assessments: HOPE introduces up to four assessment points per patient, capturing care from multiple angles during the first 30 days and at discharge.
  • Real-Time Data Capture: Unlike the retrospective nature of HIS, HOPE assessments are completed during live patient encounters, providing richer and more immediate insights.
  • Higher Stakes for Compliance: To avoid a reimbursement cut of up to 4%, agencies must ensure that at least 90% of HOPE assessments are submitted on time—a notable increase from the previous 2% penalty under HIS.
  • Public Reporting Timeline: While HIS data has been publicly available, HOPE data will not be released for public comparison until fiscal year 2028 or later, giving providers time to adapt.

*from the SimiTree blog: Understanding the Transition from HIS to HOPE

As the implementation of the HOPE tool gets closer, we will continue to share training information from CMS and other sources as it becomes available. If you need a referral to a hospice consultant to navigate the transition, please reach out to The Rowan Report.

# # #

Kristin Rowan, Editor
Kristin Rowan, Editor

Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news, and speaker on Artificial Intelligence and Lone Worker Safety and state and national conferences.

She also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing.  Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

 

“Planning for In-Home Care”

Advocacy

FOR IMMEDIATE RELEASE

Contact:                                                                       Elyssa Katz
571-281-0220
communications@allianceforcareathome.org

The Alliance’s CaringInfo Program Launches New “Planning for In-Home Care” Section

Rebrands to Align with Expansion to Serve Full Home-Based Care Continuum

ALEXANDRIA, VA and WASHINGTON, DC – CaringInfo.org, a program of the National Alliance for Care at Home (the Alliance), is expanding its resources with a new website section – “Planning for In-Home Care” – as well as a brand refresh to align with its growing audience. CaringInfo provides free resources to educate and empower patients and caregivers to make informed decisions about home, serious illness, and end-of-life care and services.

CaringInfo

While CaringInfo began with a focus on serious illness and end-of-life care and support, the program’s content is expanding to provide information and resources on the full spectrum of home-based care services. As a first step in this expansion, CaringInfo has launched “Planning for In-Home Care,” a new section on the website focused on the various types of care available at home.

The National Alliance for Care at Home CaringInfo

Planning for In-Home Care

The new section covers essential topics including when in-home care is needed, preparing for in-home caregivers, who provides in-home care services, how to find a caregiver, and how to pay for in-home care. 

“CaringInfo is a valuable resource used widely among hospice, palliative, and advance care planning experts and professionals as well as patients and families who need help and guidance.”

Dr. Steve Landers

CEO, The National Alliance for Care at Home

Landers, continued, “The launch of ‘Planning for In-Home Care’ marks an exciting step in the continued expansion of CaringInfo to provide resources and guidance on the full continuum of home-based care and to serve as a resource to all providers under the Alliance umbrella. Finding and navigating care at home can be difficult for patients and their loved ones, especially as it is often needed during life’s most vulnerable moments. These free, accessible resources help ensure everyone seeking home-based care can make informed decisions to get the support they need.”

Visual Update

The updated CaringInfo design is intended to remain familiar for return visitors who trust the site as their go-to source for making care decisions, while aligning with the Alliance’s core brand. This visual update indicates CaringInfo’s realignment to serve the full home-based care community, including home health, home care, Medicaid HCBS, palliative care, and hospice providers.

The National Alliance for Care at Home CaringInfo

CaringInfo’s goal is that all people are making informed decisions about their care. In addition to easy-to-understand information about caregiving, advance care planning, and the types of care available to those who need it, CaringInfo also offers a complete library of annotated advance directive forms for all 50 states, plus Washington, DC and Puerto Rico. The full site is available in both English and Spanish.    

Visit CaringInfo.org, which is free and available to all, to explore the full site as well as the new content.

# # #

About the National Alliance for Care at Home

The National Alliance for Care at Home (the Alliance) is the leading authority in transforming care in the home. As an inclusive thought leader, advocate, educator, and convener, we serve as the unifying voice for providers and recipients of home care, home health, hospice, palliative care, and Medicaid home and community-based services throughout all stages of life. Learn more at www.AllianceForCareAtHome.org.

©2025 The National Alliance for Care at Home. All rights reserved.

Bill to Strengthen Hospice

Admin

From the office of Earl L. “Buddy” Carter (R-GA)

Carter, Bera introduce Bill to Strengthen Palliative and Hospice Care Workforce

Reps. Earl L. “Buddy” Carter (R-GA) and Ami Bera, M.D. (D-CA) today introduced the Palliative Care and Hospice Education and Training Act (PCHETA), bipartisan legislation to invest in training, education, and research for the palliative care and hospice workforce, allowing more practitioners to enter these in-demand fields. 

Palliative and hospice care focus on providing comfort and quality of life improvements for those seriously ill, extending quality of life and reducing the length of hospital stays for many patients.

Earl L. "Buddy" Carter

“Caring for someone living with serious illness or at the end of their life is one of the most compassionate, selfless things one can do, and we must ensure that these heroes have the assistance, training, education, and tools available to provide the highest quality care possible. As a pharmacist, I understand the toll burnout takes on the health care industry, and I am committed to bolstering the workforce so nurses, doctors, and all health care workers can continue to pursue their passion for helping others.”

Earl L. "Buddy" Carter

(R-GA), U.S. House of Representatives

Ami Bera, M.D.

“As a doctor, I know how important it is to provide patients with comfort, clarity, and support when they’re facing serious illness,” said Rep. Bera. “The Palliative Care and Hospice Education and Training Act is a smart, bipartisan step to ensure more health care professionals are trained to deliver this kind of care. By expanding training programs and strengthening our health care workforce, we will make sure that patients and families have access to the care they need to manage pain, make informed decisions, and live with dignity.”

Workforce Shortage

In 2001, just 7% of U.S. hospitals with more than 50 beds had a palliative care program, compared with 72% in 2019. Those working in the field, 40% of whom are 56 years of age or older, report high rates of burnout, in response to the increasing number of patients requiring treatment. 

Reps. Carter and Bera’s bill, which has a Senate companion led by Senators Baldwin and Capito, alleviates these strains through workforce training, education and awareness, and enhanced research.

Widespread Support

“As we face a critical shortage of health professionals with expert knowledge and skills in palliative care, AAHPM applauds Representatives Carter and Bera for their leadership in introducing the Palliative Care and Hospice Education and Training Act to ensure all patients facing serious illness or at the end of life can receive high-quality care. We urge Congress to recognize the importance of a well-trained, interprofessional healthcare team to providing coordinated, person-centered serious illness care and to act now to build a healthcare workforce more closely aligned with America’s evolving healthcare needs. Advancing PCHETA will go a long way towards improving quality of care and quality of life for our nation’s sickest and most vulnerable patients, along with their families and caregivers.”

Kristina Newport, MD FAAHPM, HMDC

Chief Medical Officer, American Academy of Hospice and Palliative Medicine

“Palliative care treats the whole person, not just the disease. Ensuring health care providers can be trained in this specialized, coordinated form of care and providing funding for robust public education through the Palliative Care Education and Training Act can help increase access to palliative care for cancer patients and make their cancer journey less difficult. We commend Reps. Carter and Bera for their leadership and steadfast commitment to palliative care and to improving quality of life for patients, including those impacted by cancer.”

Lisa A. Lacasse

President, American Cancer Society Cancer Action Network

“Every person living with serious illness or facing the end of life deserves compassionate, expert care that honors their choices and helps them live comfortably on their own terms. The Alliance celebrates Representatives Carter and Bera’s leadership in introducing the Palliative Care and Hospice Education and Training Act, which will ensure families have access to the trained professionals they need during life’s most difficult moments. As our population ages, this critical investment in education and training will help us meet the growing demand for quality palliative and hospice care

Dr. Steve Landers

CEO, National Alliance for Care at Home

Supporting Organizations

Alzheimer’s Association, Alzheimer’s Disease Resource Center, Alzheimer’s Impact Movement, American Academy of Hospice and Palliative Medicine, American Academy of Pediatrics, American Academy of Physician Associates, American Cancer Society Cancer Action Network, American College of Surgeons, American Geriatrics Society, American Heart Association, American Psychological Association, American Psychosocial Oncology Society, The American Society of Pediatric Hematology/Oncology, Association for Clinical Oncology, Association of Oncology Social Work, Association of Pediatric Hematology/ Oncology Nurses, Association of Professional Chaplains, The California State University Shiley Haynes Institute for Palliative Care, Cambia Health Solutions, Cancer Support Community, CaringKind, Catholic Health Association of the United States, Center to Advance Palliative Care, Children’s National Health System, Coalition for Compassionate Care of California, Colorectal Cancer Alliance, Courageous Parents Network, The George Washington Institute for Spirituality and Health, GO2 for Lung Cancer, The HAP Foundation, HealthCare Chaplaincy Network, Hospice and Palliative Nurses Association, LEAD Coalition, LeadingAge, The Leukemia & Lymphoma Society, Motion Picture & Television Fund, National Alliance for Care at Home, National Alliance for Caregiving, National Brain Tumor Society, National Coalition for Cancer Survivorship, National Coalition for Hospice and Palliative Care, National Comprehensive Cancer Network, National Marrow Donor Program, National Palliative Care Research Center, National Partnership for Healthcare and Hospice Innovation, National Patient Advocate Foundation, National POLST Paradigm, Oncology Nursing Society, Pediatric Palliative Care Coalition, PAs in Hospice and Palliative Medicine, Prevent Cancer Foundation, Second Wind Dreams, Social Work Hospice & Palliative Care Network, Society of Pain and Palliative Care Pharmacists, St. Baldrick’s Foundation, Supportive Care Matters, Susan G. Komen, Trinity Health, West Health Institute, The Alliance for the Advancement of End-of-Life Care, Alzheimer’s Los Angeles, Alzheimer’s Orange County, Arizona Association for Home Care, Arizona Hospice & Palliative Care Organization, Association for Home & Hospice Care of North Carolina, California Association for Health Services at Home, The Center for Optimal Aging at Marymount University, Children’s Hospice and Palliative Care Coalition, Delaware Association for Home & Community Care, Florida Hospice & Palliative Care Association, Georgia Association for Home Health Agencies, Georgia Hospice and Palliative Care Organization, Granite State Home Health & Hospice Association (NH), Healthcare Association of Hawaii, Home Care Association of Florida, Home Care Association of NYS, Home Care Association of Washington, Home Care and Hospice Association of Colorado, Homecare and Hospice Association of Utah, Hospice and Palliative Care Association of Iowa, Hospice and Palliative Care Association of New York, Hospice Care and Kentucky Home Care Association, Hospice Council of West Virginia, Hospice & Palliative Care Federation of Massachusetts, Idaho Health Care Association, Illinois Hospice and Palliative Care Organization, Indiana Association for Home, Kokua Mau, LeadingAge California, LeadingAge Georgia, LeadingAge New Jersey/Delaware, LeadingAge Ohio, LifeCircle-South Dakota’s Hospice and Palliative Care Network, Louisiana Mississippi Hospice and Palliative Care Organization, Maryland-National Capital Homecare Association, Michigan HomeCare and Hospice Association, Minnesota Network of Hospice and Palliative Care, Missouri Alliance for Home Care, Missouri Hospice & Palliative Care Association, Nebraska Association for Home Healthcare and Hospice, Nebraska Home Care Association, Ohio Council for Home Care & Hospice, Ohio Health Care Association, Oklahoma Association for Home Care and Hospice, South Carolina Home Care & Hospice Association, The Oregon Hospice & Palliative Care Association, Texas Association for Home Care & Hospice, Texas ~ New Mexico Hospice and Palliative Care Organization, Virginia Association for Home Care and Hospice, VNAs of Vermont, The Washington State Hospice and Palliative Care Organization, and West Virginia Council for Home Care and Hospice.

Read full bill text here.

# # #

Earl L. Earl L. “Buddy” Carter is an experienced businessman, health care professional and faithful public servant. For over 32 years Buddy owned Carter’s Pharmacy, Inc. where South Georgians trusted him with their most valuable assets: their health, lives and families. While running his business, he learned how to balance a budget and create jobs. He also saw firsthand the devastating impacts of government overregulation which drives his commitment to ensuring that the federal government creates policies to empower business instead of increasing burdens on America’s job creators.

A committed public servant, Buddy previously served as the Mayor of Pooler, Georgia and in the Georgia General Assembly where he used his business experience to make government more efficient and responsive to the people. Buddy is serving his fifth term in the United States House of Representatives and is a member of the House Energy and Commerce (E&C) Committee and the House Budget Committee. As a pharmacist serving in Congress, Buddy is dedicated to working towards a health care system that provides more choices, less costs and better services.

A lifelong resident of the First District, Buddy was born and raised in Port Wentworth, Georgia and is a proud graduate of Young Harris College and the University of Georgia where he earned his Bachelor of Science in Pharmacy. Buddy married his college sweetheart, Amy. Buddy and Amy have three sons, three daughters-in-law and eight grandchildren.

Ami Bera, M.D. (D-CA)Congressman Ami Bera, M.D. has represented Sacramento County in the U.S. House of Representatives since 2013. The 6th Congressional District is located just east and north of California’s capitol city, Sacramento, and lies entirely within

Sacramento County.

During Congressman Bera’s twenty-year medical career, he worked to improve the availability, quality, and affordability of healthcare. After graduating from medical school in 1991, he did his residency in internal medicine at California Pacific Medical Center, eventually becoming chief resident. He went on to practice medicine in the Sacramento area, serving in various leadership roles for MedClinic Medical Group. Chief among his contributions was improving the clinical efficiency of the practice. He then served as medical director of care management for Mercy Healthcare, where he developed and implemented a comprehensive care management strategy for the seven-hospital system.

In Congress, Bera uses the skills he learned as a doctor to listen to the people of Sacramento County and put people ahead of politics to move our country forward. His priority is to work alongside people in both parties to address our nation’s most pressing challenges and make government work. Bera believes Congress should be a place for service, not for politicians who only look out to protect their own careers, pay, and perks.

Hospice Hope

Admin

by Peggy Rattarree, Principle Product Manager, Curantis Solutions

Hospice HOPE

The importance of documenting symptom impact for patient-centered care

In hospice care, the focus isn’t just on treating symptoms; it’s on improving the quality of life for patients and their families. This is where Hospice HOPE takes center stage, emphasizing the importance of documenting symptom impact to deliver truly patient-centered care. By understanding how symptoms affect each patient’s physical, emotional, and psychosocial well-being, hospice teams can provide care that aligns with their unique needs and goals.

What is hospice HOPE?

Hospice HOPE stands for Hospice Outcomes and Patient Evaluation. It’s a philosophy that places the patient’s comfort, dignity, and goals at the forefront of care delivery. Documenting symptom impact is a critical part of this approach because it provides a detailed understanding of how symptoms affect the patient’s overall quality of life.

In hospice care, every patient’s journey is unique. By actively tracking and documenting symptom impact, care providers can move beyond generic treatments and embrace a truly individualized approach that prioritizes what matters most to the patient.

Why documenting symptom impact matters?

Moves us to patient-centered care

Documenting symptom impact allows hospice teams to focus on what truly matters to the patient. Instead of simply addressing symptoms like pain, nausea, or fatigue in isolation, it provides a holistic view of how these symptoms affect the patient’s daily life. For example:

  • Pain
    • How does it limit mobility or the ability to participate in meaningful activities?
  • Fatigue
    • Is it preventing patients from spending time with loved ones?
  • Nausea
    • Is it reducing their ability to eat or enjoy meals?
Curantis Solutions Hospice HOPE

By asking these questions and recording the answers, hospice providers can better tailor interventions to manage not just symptom management but the overall patient experience.

Improves communication across the care team

In hospice care, communication is everything. Documenting symptom impact ensures that every member of the interdisciplinary team (IDT), from nurses and physicians to social workers and chaplains, has access to the same comprehensive information.

This documentation:

  • Creates a shared understanding of the patient’s condition
  • Helps align the team’s goals with the patient’s priorities
  • Reduces duplication of efforts and enhances care coordination

When everyone is on the same page, patients and families receive more seamless, cohesive care.

Hospice HOPE Communication

Supports compliance and quality standards

Regulatory bodies like CMS (Centers for Medicare & Medicaid Services) require hospices to document and monitor patient symptoms to ensure care quality. But beyond compliance, tracking symptom impact demonstrates a commitment to continuous improvement.

Documenting symptom impact allows hospices to:

  • Identify trends and gaps in care
  • Measure the effectiveness of interventions
  • Use data to advocate for better resources or innovations in care delivery

Empowers families and caregivers

When symptom impact is documented, families and caregivers gain a clearer understanding of their loved one’s condition. This transparency fosters trust and collaboration between the hospice team and the family, ensuring everyone is working toward the same goals.

For example, a caregiver might better understand why a loved one sleeps more during the day or avoids certain foods. These insights can help families feel more prepared and supported during a challenging time.

Final Thoughts

With CMS rolling out Hospice HOPE, documenting symptom impact is no longer optional. It’s the standard for compassionate, high-quality care. This shift helps hospice organizations go beyond symptom control and into whole-person care that honors each patient’s life journey.

This is part one in a two-part series on Hospice HOPE. Check back next week for part two.

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Peggy Rattarree Curantis Solutions Hospice HOPE
Peggy Rattarree Curantis Solutions Hospice HOPE

Peggy is an IT professional with over 30 years’ experience. She has defined and developed software products in industries such as grocery management, financial services, and reporting and analytics. In her 2.5 years with Curantis, Peggy has helped to shape the definition and delivery of the application. She brings a passion for agility and has been integral in transitioning Curantis to an environment of delivery on cadence, release on demand.

Peggy has a Bachelor of Music degree from University of North Texas.

©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in the Curantis Solutions blog and is reprinted here with permission. For more information or to request permission to print, please contact Curantis Solutions.

Workplace Violence in Home Health

Caregiver Safety

by Kristin Rowan, Editor

Workplace Violence and Policy Impact

Study of home health workers

A group of researchers from the University of Cincinnati, Ohio published a recent study¹ on the frequency and reporting procedures of workplace violence (WPV) in home healthcare. The study specifically addressed WPV in home healthcare, stating limited understanding of WPV in the home care setting. Most existing studies on WPV were hospital-based.

Frequency of Workplace Violence

Of the home health care workers (HHCW) surveyed, almost 37% responded that they experience both verbal and emotional violence in the workplace daily. More than 80% reported experiencing verbal aggression at some point. Physical violence is less prominent. 20% of respondants said they experience physical violence monthly. However, 56.6% said they have experienced physical violence at some point in their current agency. 76.6% of the time, the perpetrators of the violence are the patients of the HHCW.

Workplace Violence

Fig. 1 Frequency of occurrence of physical, verbal, emotional, and sexual abuse as a function of time: daily, weekly, monthly, <yearly, yearly, and never.

Reporting Workplace Violence

All of the study participants indicated they had knowledge of workplace violence reporting procedures in their agencies, but 26.7% were unsure if the policies are contained in the employee handbook. 46.7% were uncertain as to whether the agency offered WPV or de-escalation training and 66% said prevention and de-escalation training was not mandatory. Unfortunately, 40% said their management did not encourage reporting and 33% said they were not comfortable approaching management about WPV. Despite the frequency of WPV among the respondents, none of the participants reported these incidents to management

Thoughts

According to this, and other research studies on workplace violence in home healthcare, the problem is prevalent and persistent. Most HHCWs have experienced some sort of aggression, violence, or abuse in the course of performing their jobs. Of those who have, most do not report the incidents to management. Most HHCWs have not been trained in prevention or de-escalation. Even with training, HHCWs need a way to get immediate help. Unfortunately, most do not have an emergency alert system on their person during home visits.

    Solution

    Care at Home agencies, including non-medical supportive care, home health, hospice, and any other lone workers who are visiting patients in their homes, need safety policies and procedures. Agencies must include the same in the employee handbook, explain during orientation, and make available to HHCWs digitally. 

      Policies and procedures should include:

      • A safety committee comprised of management, back office staff, and field workers
      • A clearly written policy regarding physical, emotional, verbal, and sexual abuse
        • Against a patient or their family/friends by a HHCW
        • Against a HHCW by a patient or their family/friends
        • Against a HHCW by a colleague or manager
        • Against a HHCW by the environment in which they work (i.e. aggressive pets, weapons, cigarette smoking indoors, etc.)
      • A digital reporting system that employees can use without having to approach management individually
      • A clearly written policy on the management response to violence reporting
      • A clearly written policy forbidding any retaliation or discrimination against a reporting employee
      • Required research about new patients including
        • Background/History of violence and/or mental instability
        • Neighborhood safety rating
        • Family members likely to be in the home and their history of violence and/or mental instability

      Additional Tools for HHCWs

      • Training in
        • Violence prevention
        • De-escalation
        • Situational Awareness
        • Self-defense
      • A mandatory, GPS-enabled, multi-function safety device and platform to proactively manage caregiver safety and respond to incidents
      • Optional escort service for new patients
      • Mandatory escort service for new patients with a history of violence, mental issues, or incarceration

      Workplace violence against HHCWs is not “if,” but “when.” It is the responsibility of the agencies to lower the risk, lower the percentage of “whens,” and encourage reporting. If you’re not sure how to begin, hire a consultant to help you build your safety committee and write your policies. It doesn’t matter how you start implementing safety protocols, as long as you follow through and protect your employees.

      # # #

      Kristin Rowan, Editor, The Rowan Report
      Kristin Rowan, Editor

      Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news, and speaker on Artificial Intelligence and Lone Worker Safety and state and national conferences.

      She also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing.  Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

      ©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

       

      1. Obariase, E.; Bellacov, R.; Gillespie, G.; Davis, K. (2025). Assessing Workplace Violence and Policy Impact: A Cross-sectional Study of Home Healthcare Workers. Home Healthcare Now, 43(3), 150-156. doi: 10.1097/NHH.0000000000001345

      The Alliance Responds

      Advocacy

      by Kristin Rowan, Editor

      The Alliance Responds to CMS Hospice Update

      The Alliance responds to CMS-1835-P, the FY 2026 Hospice Wage Index, Conditions of Participation, and Quality Reporting Program Requirements updates. On June 10, 2025, in a 25 page letter to Dr. Mehemet Oz, CEO for The National Alliance for Care at Home Steve Landers, MD, MPH lays out the constraints and financial burdens hospice agencies will face if these updates are enacted. 

      Payment Rate Update

      Increase Less than Inflation

      In the rule for FY 2026, CMS proposes a 3.2 percent market basket increase and a .8 percent productivity decrease, yielding a 2.4 percent increase overall. According to the letter, inflation has raised medical care prices by 3.1 percent, leaving a shortfall of .7 percent. Hospices are also plagued by the same workforce shortage the rest of the medical industry faces. Workforce shortages result in fewer qualified people than there are available positions, which drives wages up. BLS data indicates the wage increase for 2025 was 4.4%. The Alliance argues that the 2.4% net increase falls well short of the actual expense increase.

      Faulty Data

      In a recent article, we outlined the process that CMS uses to determine the market basket update. The Alliance echos our information, showing the market basket forecast is well below actual increases. The Alliance further argues that the shortfall compounds, leaving the base rate increasingly smaller with each forecast. The current estimate is a 4.9% pay rate gap. CMS contends there is no way to adjust for forecast errors. The Alliance has a simple solution: manually adjust the payment rate every year when the finalized number are above the forecasted numbers BEFORE adding the next year’s payment rate increase.

      Likewise, The Alliance concurs with The Rowan Report sentiment that productivity cannot increase in hospice like it does in less labor-intensive sectors. Landers also mentions the failure to consider travel costs, the wage differences in rural areas, and the lack of reclassification options in hospice care.

      Payment Rate Recommendations

      As any well-drafted response should, The Alliance provides actionable recommendations in each section. For payment rate updates, The Alliance recommends:

      • We recommend CMS examine closely more recent data and increase final payment rates for FY 2026.
      • We urge CMS to explore all available avenues to address the forecast error shortfall, such as through a one-time adjustment.
      • We encourage CMS to collaborate with stakeholders to address the shortcomings of relying upon hospital data to determine hospice payment rates, and ways to achieve parity across provider types with respect to geographic area wage adjustments.

      HIS to HOPE Transition

      Also addressed in the letter is opposition to the timeline of the HIS to HOPE transition. The Alliance restates much of what was in the joint letter to CMS urging the delay of the HOPE tool adoption. That letter was a joint venture between The National Alliance for Care at Home (The Alliance), LeadingAge, and the National Partnership for Healthcare and Hospice Innovation (NPHI).

      The consequence of adverse outcomes cannot be understated. The risk of negative financial consequences for hospice providers is
      largely dependent this year on the success of two transitions—iQIES and HOPE— neither of which are within their control.

      Steve Landers, MD, MPH

      CEO, National Alliance for Care at Home

      HOPE Transition Recommendations

      • Considering the volatility inherent in a reporting transition of this magnitude and the lack of clear information provided to date, we respectfully request CMS waive the HOPE timeliness submission requirement for two calendar quarters post implementation.
      • We further respectfully request that CMS delay the HOPE implementation date until at least six months after CMS education and training, beyond that which is introductory and that is scheduled for spring/summer 2025, the final validation utility tool specifications are available and the application for iQIES access has been opened for hospices.

      Digital and Future Hospice Measurements

      Among the digital hospice measurements is an interoperability measurement. The Alliance supports interoperability and data exchange across medical care entities, but stresses to CMS that many hospices do not have digital EHR systems, cannot afford to maintain such systems, and have not received the federal financial support necessary to meet this objective.

      The Alliance also objects, not in theory, but in practical application, to the nutrition measure noted in future hospice measures. Nutrition for a hospice patient is vastly different than for other patients and should be implemented as a process measure, rather than having specific goals for food intake and nutrition.

      Similarly, the well-being measure is not designed for hospice care. In other sectors of healthcare, well-being incorporates measures for mental, social and physical health and focuses on curative plans. Hospice care focuses on person-centered care, emphasizing the desires of the patient as they are balanced against religious, cultural, and personal beliefs. The well-being measure must be curated to fit hospice care.

      The Alliance - Conclusion

      The Alliance values CMS’s ongoing commitment to enhancing hospice care quality,
      ensuring program integrity, and improving patient outcomes. We appreciate your
      consideration of our comments and look forward to ongoing dialogue to achieve these
      shared objectives.

      The Rowan Report - Conclusion

      The Alliance has, as always, done an exemplary job at explaining the industry position on the CMS rule. Likewise, it has outlined each step CMS should take to view the updates through a hospice lens rather than a hospital lens. We commend and support The Alliance statement and position. As this is an ongoing topic until the final rule is implemented, we will continue to provide updates as they become available. 

      If you are a member of The Alliance, you can read the full 25 page letter here.

      # # #

      Kristin Rowan, Editor
      Kristin Rowan, Editor

      Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news, and speaker on Artificial Intelligence and Lone Worker Safety and state and national conferences.

      She also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing.  Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

      ©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

       

      Painting Pictures

      Admin

      by Elizabeth E. Hogue, Esq.

      "Painting Pictures" of Patients

      Painting Pictures in clinical documentation to achieve positive audit results. As the fight against “fraud, abuse and waste” continues, responding to audits has become an ongoing burden for many providers. Providers have repeatedly been urged to “paint a picture” of patients in clinical documentation in order to help achieve positive results. “Painting a picture” of the patient, however, may have become more difficult as the use of electronic health records (EHRs) has increased. That is, it’s difficult to adequately describe patients’ conditions when there are so many boxes to check and blanks to fill in.

      Copy, Paste, Repeat

      When it comes to narrative descriptions of patients’ conditions, it is extremely tempting to “copy and paste,” “cut and paste” and/or “copy forward” previous documentation in the EHR. The copy and paste feature allows users to use the content of another entry and to select information from an original or previous source to reproduce in another location. The copy forward capability replicates all or some information from a previous note to a current note, while the cut and paste feature removes documentation from the original location and places it in another location. In addition to the obvious potential problems for quality of care related to the use of these functions, auditors are understandably skeptical of documentation that repeats itself throughout patients’ medical records.

      Painting Pictures of Fraud

      Auditors are especially likely to deny claims that include documentation that was obviously copied using the above functions, when the information copied “sticks out like a sore thumb.” If hospice staff document, for example, that “the patient eats a lot of Mexican food” over and over in clinicians’ visit notes, auditors are understandably skeptical about whether services were necessary for a hospice patient who seems to have a continuous robust appetite or whether services were, in fact, rendered.

      How to Paint the Picture

      What does it mean to “paint a picture?” If a home health patient needs wound care or injections of medications, for example, the “picture” must account for why patients or their caregivers are not performing these activities themselves. Clinicians need to describe the following in a “picture” of the patient:

      • Does the patient live alone or have caregivers?
      • Why can’t patients do wound care or self-inject medications
      • Why can’t caregivers perform these activities?
      • What attempts did clinicians make to assist patients and caregivers to provide wound care and injections?
      • Why were these attempts unsuccessful?
      • What attempts were made to find other caregivers – either paid or voluntary – who might provide these types of care?
      • What were the results of these attempts to find other caregivers?
      • Despite the initial inability of patients and caregivers to render this care themselves, what efforts did clinicians make to help ensure that they became able to do so?
      Painting Pictures

      Get the Picture?

      It’s difficult, if not impossible, to paint the above picture using only the boxes and blanks of forms in EHRs. More is needed if providers are serious about positive audit results.

      # # #

      Elizabeth E. Hogue, Esq.
      Elizabeth E. Hogue, Esq.

      Elizabeth Hogue is an attorney in private practice with extensive experience in health care. She represents clients across the U.S., including professional associations, managed care providers, hospitals, long-term care facilities, home health agencies, durable medical equipment companies, and hospices.

      ©2025 Elizabeth E. Hogue, Esq. All rights reserved.

      No portion of this material may be reproduced in any form without the advance written permission of the author.

      ©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

      AI in Home Care

      Artificial Intelligence

      by Laurie Orlov, Founder, Aging and Health Technology Watch

      The Future of AI in Home Care

      New Research Report

      Wed, 06/04/2025

      PORT SAINT LUCIE, FL, UNITED STATES, June 4, 2025 /EINPresswire.com/ — The home care industry is facing a crisis. Driven by demographic shifts, longer life expectancy, and rising rates of chronic illness and cognitive decline, the demand for in-home personal care and home health care is surging. This will accelerate as the baby boomers age into their later years – in January, the oldest of the 76 million baby boomers will turn 80. At the same time, the care industries will face a critical shortage of all categories of care delivery, with millions of additional workers needed over the next decade. Against this backdrop, AI technology has emerged to help older adults in multiple ways. In a 2023 report, The Future of AI and Older Adults, AI was already able to produce insights about a person’s health needs and offer a chatbot to help with post-hospital care. In a subsequent 2023 report, AI and the Future of Care Work, it was apparent that AI could help generate an appropriate care plan and that an ‘AI Caregiver’ role was emerging to supplement in-person care delivery. In the 2024 report, The Future of AI in Senior Living and Care, AI was being used to analyze hospital discharge information to compare patient needs to nursing home capacity. 

      Today there are many more initiatives and new possibilities for addressing multiple aspects of both private duty home care and home health operations, including assistance with recruiting and onboarding workers, using data to create and update care-related documents, and introducing AI agents that can be assigned to complete specific tasks. As current industry leaders note, AI tech is playing a role in care oversight and enabling the creating of hybrid models – an increasingly likely combination of in-person care supplemented with AI.

      This report draws insights from experts across home care, home health care, plus software and device providers, and healthcare sectors to examine how AI is currently being used and suggest what lies ahead within the next five years.

      The report can be found at this link: https://www.ageinplacetech.com/page/future-ai-home-care

      # # #

      Laurie Orlov The Future of AI in Home Care
      Laurie Orlov The Future of AI in Home Care

      Laurie M. Orlov, a tech industry veteran, writer, speaker, elder care advocate, is the founder of Aging and Health Technology Watch  market research, trends, blogs and reports that provide thought leadership, analysis and guidance about health and aging-related technologies and services that enable boomers and seniors to sustain and improve their quality of life. In her previous career, Laurie spent many years in the technology industry, including 9 years at analyst firm Forrester Research. She has spoken regularly and delivered keynote speeches at forums, industry consortia, conferences, and symposia, most recently on the business of technology for boomers and seniors. She advises large organizations as well as non-profits and entrepreneurs about trends and opportunities in the age-related technology market.  Her perspectives have been quoted in the Wall Street Journal, the New York Times, Vox, Senior Housing News, CNN Health, AARP Bulletin and Consumer Reports. She has a graduate certification in Geriatric Care Management from the University of Florida and a BA in Music from the University of Rochester. Laurie has provided testimony about technology at a Senate Aging Committee hearing and has consulted to AARP.  Advisory clients have included AARP, AOL, Argentum, Bose, Calix, CDW, Microsoft, Novartis, and Philips. Her reports include: The Market Overview Technology for Aging 2025The Future of AI in Senior Living and CareThe User Experience Needs An Upgrade 2024The Future of AI and Older and Older Adults 2023The Future of Care Work and Older Adults 2023The Future of Sensors and Older Adults 2022Beyond DIY: The Future of Smart Homes and Older Adults 2021, and The Future of Wearables and Older Adults 2021. Laurie has been named one of the Women Leaders in VoiceTop 50 Influencers in Aging by Next Avenue and one of the Women leading global innovation on AgeTech. 

      ©2025 by Aging and Health Technology Watch. All rights reserved. This introduction and link are printed with permission from the author. For more information or to request usage rights, please contact Laurie Orlov

      BREAKING NEWS: Intrepid USA Files Bankruptcy

      Breaking News

      by Kristin Rowan, Editor

      *Editor’s note: This article has been updated to remove inaccurate information from the Intrepid USA website.

      Intrepid USA Files Bankruptcy

      Intrepid USA, once among the largest providers of home health and hospice services, files bankruptcy in Texas. With more than $90 million in revenue in 2023, Intrepid operated more than 60 home health and hospice locations in 17 states. The Chapter 7 filing leaves no road to recovery. Chapter 7 allows the company to liquidate assets and distribute the proceeds. According to the Texas Southern Bankruptcy Court, Intrepid USA filed a voluntary petition for Chapter 7 bankruptcy on May 29, 2025.

      Troubled History Plagues Company

      Intrepid USA has a troubled past that it seems may have caught up with them. The U.S. Department of Justice (DoJ) alleges that between 2016 and 2021, Intrepid home healthcare agencies engaged in fraud. In violation of the False Claims Act, Intrepid filed Medicare claims for patients who did not qualify for home health, services that were not medically necessary, services provided by untrained staff, and services that were never provided. In August, 2024, Intrepid agreed to pay $3.85 million to resolve the allegations. The allegations were brought to the DoJ by two former employees of Intrepid under whistleblower provisions.

      This is not the first DoJ lawsuit against Intrepid USA. In 2006, when Intrepid owned 150 agencies across the country, the company entered into an $8 million settlement agreement to resolve similar allegations. The DoJ alleged that from 1997 to 2004 Intrepid violated the False Claims Act by billing Medicare and TRICARE for services not provided by a qualified person, failing to maintain complete documentation for its claims, and other violations of Medicare regulations. Additionally, the DoJ alleged that Intrepid, in 2002 and 2003, fraudulently billed Medicaid for home care services provided to patients who were hospitalized at the time of the supposed care.

      Private Equity Backing

      Sometime around Q3 of 2006, Intrepid USA received financial backing from Patriarch Partners, led by Lynn Tilton. In August of 2020, Patriarch filed a notice of removal with the Supreme Court of New York. In 2021, Intrepid announced it was gearing up for rapid growth fueled by new private equity investors. Then CEO John Kunysz indicated the infusion of capital would fund opportunities for growth through acquisition.

      Divest, not Acquire

      Despite the influx of capital and the plan to grow through acquisition, by 2024, Intrepid was selling its assets. In August of 2024, Humana acquired 30 Intrepid branch locations and rebranded them under the CenterWell Home Health brand. The sale was part of Patriarch Partners’s Zohar Funds bankruptcy case. In November of 2024, New Day Healthcare acquired Intrepid’s hospice locations in Missouri and Texas.

      $0 Revenue; 0 Value

      The bankruptcy filing shows that Intrepid USA had $90 million in revenue in 2023, $50 million in revenue in 2024, and $0 in revenue so far in 2025. Chapter 7 bankruptcy is usually supervised by the court, allowing the filing company to sell assets without having to use the revenue generated by the sale to pay off debts. Intrepid listed $1 to $10 million in assets and $88 million in debts at the time of the filing. 

      Intrepid USA files bankruptcy
      Intrepid USA Files Chapter 7 Bankruptcy

      Who will take the loss?

      The Intrepid USA website still lists 55 active home health and hospice locations in 11 states. However, 30 of those locations are now listed on the CenterWell website and at least 5 other locations were part of the sale to New Day Healthcare. It is unknown if Intrepid has any locations still in operation. The company did not respond to our request for a statement.

      The website also has a list of partners and investors. The Rowan Report reached out to the partners with whom we are familiar for more information. We will provide updates from them once we reach them.

      Final Thoughts

      The recent divestiture of home health and hospice locations to New Day and CenterWell will hopefully minimize the number of patients who are losing their home health or hospice provider. Millions of dollars in future fraudulent claims will remain in the Medicare, TRICARE, and Medicaid coffers. Conversely, the partners and investors in Intrepid USA may face some loss. We will provide any important updates and comments from the impacted companies as available.

      # # #

      Kristin Rowan, Editor
      Kristin Rowan, Editor

      Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news, and speaker on Artificial Intelligence and Lone Worker Safety and state and national conferences.

      She also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing.  Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

      ©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

       

      Fraudsters Arrested, Oz Issues Warning

      CMS

      by Kristin Rowan, Editor

      Fraudsters Arrested, Oz Issues Warning

      Fraud in California

      Fraudsters arrested in West Covina, CA this week were allegedly running a Medicare scheme. Authorities arrested hospice owner-operator Normita Sierra. They charged her with nine counts of health care fraud, one count of conspiracy, and four counts illegal remuneration (kick-backs) for health care referrals. The U.S. Attorney’s Office named co-conspirator Rowena Elegado. They also arrested her and charged her with one count of conspiracy and four counts of illegal remuneration for health care referrals.

      Kickbacks

      Sierra and Elegado worked together to pay marketers to recruit patients who did not have a hospice referral from their PCP and who were not terminally ill. Some of the kickbacks paid to marketers were as high as $1,300 per patient per month. After six months, the patients were referred out to Sierra’s home health company.

      Medicare Claims

      According to the U.S. Attorney’s Office, from 2018 to 2022, Sierra’s hospice agences submitted $4.8 million in fraudulent claims. Of those claims, Medicare paid approximately $3.8 million.

      Dr. Oz Issues Warning

      In a video statement, Dr. Oz explained how Medicare recipients are falling victim to scams. Sales people call, email, and even knock on your door, offering advice, free samples, and referrals. These marketers have one goal: get you sign a piece of paper. That paper signs you up for hospice care and agrees to allow a specific hospice agency to provide that care. The hospice agency then bills Medicare for services they never provide. Watch the video statement here.

      HHS OIG Issues Consumer Alert

      In a similar statement, HHS issued a consumer alert regarding DME companies. The alert warns that some DME companies are contacting Medicare beneficiaries. They claim to work for or on behalf of Medicare. Once they receive the patient’s Medicare number, they bill Medicare for unnecessary medical items. These items include urinary catheters, knee and back braces, orthotic braces, and prescription drugs, which may or may not ever be sent to the patient. HHS urges enrollees not to give their Medicare number to anyone. Further, they suggest regulary reviewing items charged to insurance, and refusing delivery of any medical supply not ordered by a physician.

      Oz Issues Warning
      Fraudsters Arrested

      Combating Waste, Fraud, and Abuse

      Dr. Oz and CMS have spoken numerous times about combatting the waste, fraud, and abuse withing the Medicare and Medicaid systems. Originally a strong proponent for Medicare Advantage, Oz has promised to audit MA after discovering the government pays more for MA than traditional Medicare. Oz also promised to reduce the amount of prior authorization requests needed before a patient gets services. Oz responded to the Republican-backed House bill requiring more oversight on Medicaid eligibility. Oz indicated that some Medicaid patients are enrolled in more than one state and that Medicaid is paying for able-bodied patients. The waste, fraud and abuse across Medicare and Medicaid is costing the government between $1 and $10 billion and Dr. Oz plans to find it and make significant changes to the management of the system.

      A Cautionary Tale for Hospice Providers

      You may be thinking, “What does this have to do with me?” Unfortunately, even the most scrupulous hospice agencies can fall prey to marketers running schemes. There are legitimate referral resources in the market who can help your agency get more referrals and more clients. There are also underhanded marketers who know how the system works. These predators will promise new referrals (for a fee) and then enroll uneligible patients without your knowledge. If you are working with or looking for a referral partner for your hospice agency, use one that is referred by someone you trust, and/or do a lot of research on the company history before working with anyone. Be especially wary of the ones who promise much more than what most referral companies offer.

      # # #

      Kristin Rowan, Editor
      Kristin Rowan, Editor

      Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news, and speaker on Artificial Intelligence and Lone Worker Safety and state and national conferences.

      She also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing.  Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

      ©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

       

      Delay HOPE Tool

      Advocacy

      by Kristin Rowan, Editor

      Advocacy Groups to CMS:

      Delay HOPE Tool Implementation

      “Delay HOPE Tool Implementation,” say multiple hospice advocacy groups. LeadingAge, the National Alliance for Care at Home (The Alliance), and the National Partnership for Healthcare and Hospice Innovation (NPHI) are urging CMS to delay the transition from HIS to HOPE. The three groups sent a joint letter to Dr. Mehmet Oz, CMS Administrator, earlier this week.

      “Our associations remain fully committed to the [Hospice Quality Reporting Program (HQRP)], including the payment penalties for non-compliance, and recognize the critical importance of accurate, timely data submission to inform the delivery of high-quality hospice care. However, we have serious concerns about the potential for successful implementation of the HOPE tool.”

      LeadingAge, The Alliance, NPHI

      Hospice Advocacy

      The concerns over agency readiness to implement the new tool center on the new reporting platform. Hospice agencies state they don’t have all the necessary information to develop a workable tool for submission. Therefore, the agencies have asked CMS to delay the implementation of the HOPE tool. They have called on CMS to wait until six months after agencies have access to education, training, and final validation specifications.

      Hospice Rule Penalty

      The hospice program through CMS requires substantial reporting for payment. Hospices that do not submit the required 90% of records, they receive an annual payment penalty of 4%. Combined with lower than sustainable payment increases, the 4% penalty results in a lower reimbursement rate over prior years. The associations worry that the lack of information and education will lead to lower reporting. In turn, the lower reporting lowers reimbursement rates. For hospices that are already struggling to survive, the penalty is devastating. The letter to CMS asked to waive the timeliness requirement for two quarters after implementation.

      HOPE Tool Lacks Validation

      CMS will have a Validation Utility Tool that agencies will need to use in order to ensure their software can successfully submit their data. CMS has not released the tool and indicates they may not until sometime in September. The HOPE tool is scheduled for implementation in October. There is not enough time between release of the validity tool and implementation of the HOPE tool for proper testing.

      Hospice Agencies Lack Validation

      In addition to validating data submission, hospice agencies have to enroll in the new submission portal, iQUIES. Enrollment requires a privacy security official and other staff. Additionally, it requires an application to access the system, background checks, and other actions. Thus far, hospice agencies do not have access to begin this process and there is no indication of how long it will take. The associations are concerned that the process may also involve significant financial cost to hospice agencies.

      Resources

      CMS released the Hospice Outcomes and Patient Evaluation (HOPE) Guidance Manual v1.01, a 138 page PDF, available here. The manual includes links to other resources for hospice agencies. Namely, a webpage with information on HOPE Data Submission Specifications has a “final” version of data specs available for download. Additionally, there are links to the Main Page here and technical information and updates here. The document urges vendors to register to get updates and important announcements.

      Final Thoughts

      There is no information yet as to a response to the letter from CMS. Thus far, CMS is still planning on keeping the October 1, 2025 HOPE implementation date. We will continue to report on updates from CMS and the advocacy groups.

      # # #

      Kristin Rowan, Editor
      Kristin Rowan, Editor

      Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news, and speaker on Artificial Intelligence and Lone Worker Safety and state and national conferences.

      She also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing.  Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

      ©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

       

      Update is Not an Increase

      Hospice

      by Kristin Rowan, Editor

      Updates to Hospice Rule

      On April 11, 2025, the Centers for Medicare and Medicaid Services (CMS) issued their proposed rule for hospice rates, Conditions of Participation (CoPs) and face-t0-face encounter requirements for FY 2026. The proposed rule also includes a change in regulatory text for the Hospice Quality Reporting Program.

      Following Executive Order 14192, an attempt to reduce the expense attached to following Federal regulations, CMS is seeking feedback on streamlining regulations and reducing expenses. The RFI to submit responses can be found here.

      Payment Updates

      The proposed update to the hospice payment rate yields a net increase of 2.4 percent. This change includes a 3.2 percent market basket increase based on the estimate cost increase for inpatient hospitalization. The 0.8 percent productivity adjustment offsets the market basket increase. The quality data penalty of 4 percent remains in place.

      Market Basket Objections

      Not for the first time, commentors on CMS proposed rules objected to the use of the hospital wage index in determining hospice pay rates. According to a report from the Federal Register, a few commenters on the FY 2025 payment update opposed using the IPPS wage index to determine the hospice wage index. According to the commenters, the hospital wage index uses cost report wage data that excludes hospice wage costs. The exclusion of hospice costs skews the accuracy of wage adjustments for hospice providers.

      In response to the same proposed rule, MedPAC recommended that wage index policies be repealed and replaced by new Medicare wage index systems that use all-employer, occupation-level wage data; account for wage differences across geographical areas, and match wages in adjacent local areas. 

      CMS Ignores Objections

      Despite years of comments, objections, and suggestions to update the hospice wage index calculations using more accurate data, CMS continues to insist that using the pre-floor and pre-reclassified hospital wage index is the more appropriate for determining hospice payment rates. CMS states that this position is “longstanding and consistent with other Medicare payment systems.”

      Productivity Adjustment

      The productivity adjustment started with the Affordable Care Act. It’s stated purpose is to “reduce Medicare spending by recognizing that hospitals can improve their efficiency and productivity.” Average efficiency and productivity gains in all private non-farming businesses form the productivity adjustment.

      The most recent document from CMS about the productivity adjustment comes from 2022, using data from 2019. The report shows that hospital growth falls far below the average growth of private non-farming businesses. Using two different methods of calculations, hospital growth falls between 0.2 and 0.3 percent. Non-farming business growth is 0.8 percent. 

      Labor Productivity

      CMS uses labor productivity as its measure for the productivity adjustment for Medicare hospitals and hospices. The estimate for labor productivity across all private non-farming businesses is 2.0 percent. The calculation for hospital labor productivity is 0.8 percent. This is the number used in this year’s productivity adjustment. Actual labor productivity growth in hospitals from 1993 to 2018 was 0.4 percent.

      Quality Reporting Reduction

      Hospices that do not submit the required quality data incur a payment reduction of 4 percent. This yields a 1.6 percent decrease over last year’s rates after factoring in the 2.4 percent increase. Quality data reporting includes the HIS tool, administrative data, and CAHPS hospice survey. The threshold to avoid the 4 percent reduction includes submitting at least 90 percent of HIS records within 30 days of an event date and ongoing monthly participation in CAHPS surveys.  The HOPE reporting tool replaces the HIS system beginning October 1, 2025. These requirements are not changing with the FY 2026 proposed rule, with the exception of the change from the HIS tool to the HOPE tool.

      Comment from The Alliance

      In last week’s newsletter, we summarized Dr. Steven Landers’s keynote address from the New England Home Care & Hospice Conference and Expo. Always passionate about care at home, and particularly about hospice, which he describes as “a national treasure,” Dr. Landers strongly stated that an “update is not an increase” when it doesn’t keep up with inflation and pay increases. 

      Final Thoughts

      Every year, CMS, MedPAC, and HHS make changes to hospice and home health payment rates based on faulty information that doesn’t account for the nature of the work or the person-centered requirements of the industry. Non-farming industries can increase efficiency and productivity in myriad ways that cut staff. We see it in grocery stores with the increasing number of self-checkout lines. We see it in restaurants with QR code menus, ordering kiosks, and payment kiosks. There is no substitute for one-on-one contact in a home setting for care at home, particularly in hospice. Nurses can’t take on enough more patients in a day to make a meaningful impact on efficiency and productivity without sacrificing quality of care.

      AI for Efficiency and Productivity

      I’ve been speaking for some time now on the advantages of using augmented and generative intelligence in care at home. As long as CMS continues to lower reimbursement rates using the collective productivity rates of impertinent industries, care at home has to embrace the technology that increases productivity and efficiency in the office and in the field. Talk to text, documentation, scheduling, onboarding, and data analytics are readily available through AI platforms and drastically reduce costs across departments.

      You can read about some of the AI tools here. For more information or to engage our consulting services for AI adoption, contact me directly.

      # # #

      Kristin Rowan, Editor
      Kristin Rowan, Editor

      Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news, and speaker on Artificial Intelligence and Lone Worker Safety and state and national conferences.

      She also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing.  Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

      ©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

       

      That’s a No-No

      Admin

      by Elizabeth E. Hogue, Esq.

      No-no # 1

      “No-No” may seem like something you would say to a toddler, but there is a list of things agency owners do that they should not do. Many of these are things providers may not often consider. This article focuses on the use of private duty services by hospice and home health patients, and what hospices and home health agencies cannot do with regard to aide services.

      Aide Services

      Both home health and hospice services are usually intermittent and provided in patients’ homes.  Patients and their families may elect to utilize the services of private duty/home care companies for additional assistance. At the same time, hospice and home health patients may receive aide services from hospices and home health agencies. 

      Conditions of Participation no-no

      Conditions of Participation

      According to Medicare Conditions of Participation (CoPs), hospice and home health aides can only provide personal care services, including bathing. Aides provided by private duty/home care companies may also provide personal care. Unlike aides provided by hospices and home health agencies, however, they can provide additional services; such as laundry, food preparation, light housekeeping, shopping, and running errands.

      Private Duty Services

      When patients use private duty services, they are often paying for these services out of their own pockets. Even if they have long-term care insurance, patients still bear the financial burden of paying for private duty services. Longterm care insurance often costs thousands of dollars that patients probably paid for themselves. Patients usually pay by the hour for these services. 

      Private Duty Aide Services No-No

      That's a No-No

      Patients may, of course, utilize private duty/home care services to perform any of the services described above. It seems, however, that hospices routinely tell patients who have private duty/home care that they will not provide aide services because private duty/home care aides are able to provide personal care for patients.

      Breaking it Down

      Here is an example: A hospice admitted a bedridden patient with urinary and fecal incontinence. The patient and caregiver requested aide services from the hospice five days a week to bathe him. He paid for a few hours of private duty/home care services each day. The hospice refused to provide aide services five days a week to bathe him because he had private duty/home care services. No-no!

      Compelled to Provide Care

      ospices must provide aide services consistent with patients’ needs related to their terminal illnesses. In the example above, the patient clearly had a need for aide services five days a week. If patients and their caregivers state that they prefer to use private caregivers for personal care, then hospices must document the refusal of hospice aide services offered, consistent with applicable standards of care. Then hospices are not required to provide aide services.

      Profiteering

      When hospices deny aide services that are consistent with applicable standards of care and require patients and caregivers to use private duty/home care services, hospices are shifting the cost of aide services onto patients and their families. Patients and their families may have to pay for additional private duty/home care services to meet patients’ needs. The result for hospices is that they do not incur the costs of aide services, thereby increasing their profits at the expense of patients and their families. 

      If hospice staff members who refuse to provide aide services to patients and require patients and their families to use private duty/home care services instead are compensated in any way based on the financial performance or profitability of the hospices, let’s hope they look good in orange jumpsuits!

      Intent to Defraud

      If the private duty/home care services are being paid for by any federal or state health care program; such as Medicaid, Medicaid waiver, VA, or TriCare; then both home health agencies and hospices have engaged in fraudulent conduct by shifting costs that they should have incurred onto other federal government programs. 

      God forbid that the hospice also owns the company from which patients receive private duty/home care services! Then hospices are limiting their costs while profiting from patients and their families.

      Dig Deep and Find Your No-No's

      Now is the time for all home health agencies and hospices especially to audit patients’ records to make certain that all patients have been offered services that they are required to provide. If patients and their families choose to use private duty/home care aides instead, documentation must show that they were offered the services but chose to use private duty/home care aides.

      No-No's Final Thoughts

      The bottom line is that hospices and home health agencies must always provide services needed by patients.  Patients may choose to pay for services that are paid for by the Medicare hospice or home health benefits. Patients cannot be required to pay for services privately that hospices and home health agencies must provide. Unacceptable!

      This article is the first in a series of “No-no” items for agency owners.

      # # #

      Elizabeth E. Hogue, Esq.
      Elizabeth E. Hogue, Esq.

      Elizabeth Hogue is an attorney in private practice with extensive experience in health care. She represents clients across the U.S., including professional associations, managed care providers, hospitals, long-term care facilities, home health agencies, durable medical equipment companies, and hospices.

      ©2025 Elizabeth E. Hogue, Esq. All rights reserved.

      No portion of this material may be reproduced in any form without the advance written permission of the author.

      ©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

      HIS to HOPE

      Admin

      by Vicki Goodman, CRO at Curantis Solutions

      HIS to HOPE Transition in Hospice Care

      What You Need to Know

      As a hospice nurse, I am excited to share pivotal news that will significantly impact our field starting October 1st. In case you have been living under a rock, we are transitioning from the Hospice Item Set (HIS) to the Hospice Outcomes and Patient Evaluation (HOPE). This change is not just a modification in terminology; it represents a transformative shift towards a more patient-centered and holistic approach to hospice care. In this article, we will explore what this transition entails, its benefits, and how it will affect our daily practices.

      Understanding the Transition from HIS to HOPE

      The move from HIS to HOPE signifies an essential evolution in our approach to patient care. While HIS primarily focused on data collection and compliance with regulations, HOPE emphasizes measuring patient outcomes, quality of care, and overall patient experience. This transition encourages us to engage more deeply with our patients and their families, ensuring that their unique needs and preferences are at the forefront of the care we provide.

      What is HOPE?

      HOPE stands for Hospice Outcomes and Patient Evaluation. This new framework highlights several core principles:

      • Patient-Centered Care
        • Focusing on individual patien needs and preferences
      • Quality of Care Assessment
        • Evaluation how well we meet those needs
      • Holistic Approach
        • Considering emotional, spiritual, and psychological factors in addition to physical health

      Benefits of HOPE in Hospice Care

      The adoption of the HOPE framework offers numerous advantages for both patients and healthcare providers:

      • Improved Patient Engagement
        • By prioritizing patient preferences, we can foster stronger relationships and enhance the overall care experience
      • Enhanced Quality of Care
        • Focused outcomes assessment allows us to identify areas for improvement and implement best practices
      • Recognition of Care Quality
        • HOPE enables us to demonstrate the effectiveness of our care, leading to greater recognition of our contributions in hospice settings

      HIS to HOPE Key Differences

      Understanding the distinctions between HIS and HOPE can help clarify the shift in our practices. Here are some key differences

      HIS to HOPE Vicki Goodman Curantis Solutions

      The Role of Hospice Nurses in the HOPE Framework

      As hospice nurses, our role in implementing HOPE will require a significant mindset shift. Here’s how we can adapt our practice:

      • Engage With Patients and Families
        • Actively involve them in care planning and decision-making
      • Assess Holistically
        • Look beyond clinical data to include emotional and spiritual assessments
      • Collaborate with Interdisciplinary Teams
        • Work closely with all caregivers to ensure a comprehensive approach to patient care

      By integrating these principles into our daily practice, we can enhance patient experiences and outcomes, ultimately providing the compassionate care that is the hallmark of hospice services.

      Acknowledging Our Impact

      As we transition to the HOPE framework, it’s essential to take a moment to give ourselves credit for the incredible work we already do. For most of us, patient-centered care has been at the heart of our practice long before HOPE was introduced. This new framework serves as validation, providing a structured approach to highlight the compassionate, individualized care we consistently offer.

      Getting Prepared

      The transition from HIS to HOPE marks an important chapter in the hospice care journey. Prepare for the transition with partners who understand the complexities and challenges that come with such significant changes. Specifically, work with a software and service company designed to ensure that your hospice team can seamlessly adapt to the HOPE framwork without sacrificing the quality of care. 

      About Curantis Solutions

      From comprehensive training to state-of-the-art data management systems, we provide everything needed to make this transition as smooth and effective as possible. With Curantis Solutions, you can be confident that no matter how the standards evolve, you will always be at the cutting edge, providing compassionate, patient-centered care. t Curantis, we understand the unique challenges faced by hospice and palliative care organizations. Our commitment to providing exceptional support ensures that you can focus on what matters most—delivering compassionate care to your patients. We pride ourselves on our quick response times, we deeply listen to our clients, and are easy to get ahold of when you need us. When partnering with Curantis Solutions, we guarantee we have support you can depend on.

      # # #

      Vicki Goodman
      Vicki Goodman

      Vicki Goodman, RN, BSN, MHA is an accomplished healthcare professional with a strong background in post-acute care, SaaS sales. With a proven track record of driving revenue growth, Vicki has successfully orchestrated sales strategies and marketing initiatives with over 30 years of experience in the home health and hospice EHR industry. Prior to joining Curantis Solutions, Vicki was VP, Enterprise Sales at Matrix Care.

      She is an RN and BSN graduated of East Carolina University and received her MHA from University of North Carolina at Chapel Hill. She credits a lot of her success to collaborating with product and marketing teams creating an unstoppable engine. We are thrilled to have her join the Curantis Solutions family and look forward to the continued growth under her leadership.

      ©2024 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in Healthcare at Home: The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

      Humana Thyme Agreement

      Clinical

      by Kristin Rowan, Editor

      Palliative Care for Medicare Advantage Members

      Cancer is one of the highest leading causes of death in the United States, second only to heart disease. The challenges for cancer patients are not only physical, but emotional and financial as well. The consequences of these challenges are often devastating to the patient and their families. Providing additional care, support, and pharmaceutical interventions through value-based care can improve patient outcomes and reduce out-of-pocket costs.

      Thyme Care

      Thyme Care is a Nashville-based cancer treatment center that operates in seven states. The centers provide not just treatment, but cancer care navigation, designed to work within the value-based framework, keeping the patient at the center of care. Thyme Care includes an oncology care team, a patient app with multiple resources and 24/7 access to support. Patient surveys track symptoms and reduce barriers to care. This approach combines cancer treatment and palliative care for whole-person cancer care support.

      Palliative Care

      Palliative care works alongside medical care to improve the quality of life for the patient, addressing physical, emotional, and spirtual needs. Strictly speaking, it is not medical care, and not specifically covered by most insurance plans. The out-of-pocket costs for palliative care can be extremely high, making this kind of care an inaccessible amenity for most patients.

      Humana Thyme Palliative

      Value-Based Care

      Value-based care reimburses care providers partially based on patient outcomes and patient satisfaction. Providers also share the financial risk of care with health insurance companies. Care providers who can both improve outcomes and patient satisfaction can be reimbursed more through health insurance plans, which can cover the costs of palliative care, even when it is not explicitly covered by the plan.

      Humana

      Humana is a payer with plans for Medicare, Medicaid, and Individual/Family beneficiaries. The Medicare Advantage value-based care plans allow Humana to disperse payments for covered services in partnership with care provider teams across a patient’s care journey. The better the outcome and satisfaction, the more Humana can pay a provider for care. Better outcomes often means reduced hospital visits, a longer time at home before requiring skilled nursing facilities, and lower costs.

      Humana Thyme Palliative Care Collaboration

      The recently announced partnership between payer and provider will give eligible patients access to palliative care support as part of the whole-person cancer care navigation provided by Thyme. Humana patients can also receive, as needed, 24/7 virtual care, medication guidance, symptom management, chronic condition management, community-based resources, financial assistance, transportation, food assistance, and/or access to stable housing.

      Kristin Rowan, Editor
      Kristin Rowan, Editor

      Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news. She also has a master’s degree in business administration and marketing and runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing.  Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

      ©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com