June 1, 2026 Washington, DC — In comments submitted to the Centers for Medicare and Medicaid Services (CMS) on the proposed FY2027 Hospice Wage Index and Payment Rule, LeadingAge, the association of nonprofit and mission‑driven providers of aging services, including hospice, urged the agency to adopt policies that strengthen, not undermine, access to high‑quality, mission‑driven hospice care. The organization expressed deep concern that, if implemented, several of the rule’s proposals would impose new burdens on hospices without addressing the underlying contributors to nonhospice spending.

“Nonprofit and mission‑driven hospices deliver high‑quality, person‑centered care that supports older adults and families through some of life’s most difficult moments,” said Katie Smith Sloan, president and CEO of LeadingAge. “Our members consistently invest in interdisciplinary teams, bereavement services, and community‑based supports that exceed minimum requirements—yet they operate with some of the thinnest margins in the sector. As CMS considers changes via this most recent proposed rule, it is essential that regulatory updates strengthen, rather than destabilize, access to compassionate, high‑quality hospice care.”

In comments, LeadingAge explains how the agency’s current proposals would hold hospices accountable for spending they do not generate and cannot control. “Nonhospice spending is billed to CMS by other Medicare providers and suppliers. …Individual hospice agencies do not have this authority.”

Rather than impose new requirements that will burden providers and confuse families, we urge the agency to focus on oversight of nonhospice billers “CMS should be reviewing the spending at the time of the claim and denying inappropriate billing from these providers.”

Regarding the Service and Spending Variation Index (SSVI), which is a multi-factor indicator meant to identify hospices with concerning utilization or spending patterns, we support its intent. In fact, we have long asked CMS to look at multiple factors when evaluating whether to undertake additional oversight in hospice. However, because CMS’s proposed use of the nonhospice spending measure within the SSVI “lacks transparency, disregards the influence of size and scale, includes questionable data, and is entirely inactionable for hospices,” we express concern that the use of nonhospice spending in the SSVI threatens to do expressly the opposite of the intent of that metric. That is, target the wrong providers. Applying such a measure, we say in our comments, to determine audit risk or program integrity actions would unfairly penalize compliant providers while failing to curb inappropriate billing by Part A, B, and D suppliers, which is the true source of nonhospice spending.

LeadingAge also raised significant concerns about CMS’s proposal to require hospices to provide, at the time of election, the hospice election statement addendum to all beneficiaries. This requirement is unnecessary and duplicative and would increase administrative burden, confuse families, and divert resources away from direct care. As we state in our comments, “If the purpose of the addendum is simply to save time and reduce cost burdens to nonhospice providers, there is already a mechanism in place with the current addendum requirements. Nonhospice providers can request this information today and are not.”

Additionally, in our comments we urge CMS to address the following concerns by taking specific actions:

• Remove the nonhospice spending measure from the SSVI, as it is opaque, methodologically flawed, and entirely outside hospice control.
• Reject the proposal to require a universal hospice election statement addendum, which adds burden without improving program integrity.
• Increase transparency around SSVI methodology, including how thresholds are set, how scores will be used, and how CMS will ensure consistent application across contractors.
• Release further guidance on telehealth and the face-to-face recertification during the moratorium and explain how they will be judging when the moratoria should end.
• Expand community-based palliative care, but such expansion must be funded adequately and must not be structured solely as a bridge to hospice enrollment.
• Ensure that program integrity tools do not penalize mission‑driven providers, particularly those serving high‑acuity patients, nursing facility residents, or rural communities.