Efforts to establish potential payment mechanisms for high-acuity palliative services within the Medicare Hospice Benefit will require greater clarity from regulators, according to the Coalition to Transform Advanced Care (C-TAC).

The U.S. Centers for Medicare & Medicaid Services’ (CMS) 2025 proposed hospice payment rule contained a request for information (RFI) on the potential implementation of reimbursement pathways for “high intensity palliative care services,” such as chemotherapy, blood transfusion and dialysis.

CMS in its proposed rule indicated that, “Hospice care changes the focus of a patient’s illness to comfort care (palliative care) for pain relief and symptom management from a curative type of care.”

CMS’ proposal language could further complicate widespread misunderstanding, poor awareness and access related to higher intensity palliative treatments, according to the serious illness care advocacy organization C-TAC. This could result in deepening conflation of hospice and palliative care, the organization indicated.

“We pointed out the misleading alignment of the terms ‘comfort care’ and ‘palliative care,’” C-TAC stated in its recent recommendations to CMS. “The use of the term ‘palliative’ for treatments in this RFI was problematic.”

CMS in the proposed rule defined palliative services under the Medicare Hospice Benefit as patient- and family-centered care that optimizes quality of life by anticipating, preventing and treating suffering. This definition could complicate hospices’ ability to accurately and appropriate bill for palliative care, C-TAC stated.

The agency proposed that high acuity palliative treatments could be offered throughout the continuum of a patient’s illness trajectory and includes addressing their physical, intellectual, emotional, social and spiritual needs. These services would also include facilitating patient autonomy, access to information and choice, CMS proposed.

The proposed language around palliative care may be confusing when it comes to deciphering the types of services that could be reimbursable in the hospice realm, according to C-TAC.

“Palliative care encompasses care well before that end-of-life period and using the umbrella term ‘palliative care’ in this context is inaccurate, as not all palliative care is hospice or comfort care,” the organization said. “The historic language about curative vs. palliative has always been erroneous as chronic conditions, such as heart failure or diabetes, were never curable. And so, any treatment for them is technically palliative in that it helps optimize function and quality of life, but doesn’t cure the underlying illness.”

C-TAC’s recommendations featured four key areas that would help narrow and standardize the scope of reimbursable palliative care services in hospice payment. These included further clarification of the palliative treatments covered under the hospice benefit to new Medicare-certified providers.

The organization also suggested inroads to ensure program integrity and curb fraudulent billing activity of palliative care in the hospice space.

C-TAC’s recommendations are as follows:

• Clarifying with new hospice enrollees which palliative treatments will be covered and included in the hospice plan of care and expanding those options.
• Having hospice medical directors or nurse case managers coordinate any additional disease-modifying treatment with other health care specialists involved.
• Providing payments to the clinician or entity delivering these disease-modifying treatments in collaboration with the hospice organization.
• Recognition that additional payment for high-cost, disease-modifying treatments could allow bad actors to take advantage of them. This would require tight monitoring to flag and reduce that.