The U.S. Centers for Medicare & Medicaid Services’ (CMS) proposed 2.4% hospice base rate increase is woefully inadequate, and new physician attestation requirements may place undue burdens on providers, according to comments from the National Alliance for Care at Home.

The Alliance on Tuesday released its public comments on the 2026 hospice payment rule, which stated that the proposed increase will not adequately cover hospices’ rising costs for supplies, labor, travel and other expenses. 

For Fiscal Year 2026, CMS proposed a hospice market basket percentage increase of 3.2% based on a 2024 forecast of the inpatient hospital market basket, before application of the required productivity adjustment. After the productivity adjustment, this comes to a 2.4% payment bump. CMS made a corresponding proposal to set a hospice cap amount of $35,292.51 for FY 2026.

“The proposed 2.4% payment update for FY 2026 will not sufficiently account for the cost increases that hospices continue to face,” the Alliance indicated in its comments. “General inflation, particularly in the health care sector, continues to be higher than historical norms. According to the U.S. Bureau of Labor Statistics (BLS), the medical care price index rose 3.1% over the 12 months ending April 2025.”

The Alliance also questioned CMS’ methodology for determining the rate update. By law, the Medicare hospice payment rate update is tied to the inpatient hospital market basket forecast. These forecasts have significantly underestimated actual inflation, leading to payment rate updates that lagged behind actual cost growth, particularly since the COVID-19 pandemic, according to the Alliance.

Between Fiscal Years 2021 and 2025, this has resulted in a payment rate shortfall of 4.9%, the Alliance said in its comments. This represents approximately $1.3 billion in annual underpayments to hospices.

“In this context, the proposed 2.4% FY 2026 payment rate update is insufficient to keep pace with hospices’ input costs,” the Alliance said. “Indeed, without a more robust increase, many hospice providers will continue to operate under severe financial strain, ultimately threatening patient access to end-of-life care when individuals are most vulnerable.”

The Alliance also called for a delay in implementation of the Hospice Outcomes and Patient Evaluation (HOPE) quality measurement tool until six months after CMS training and education become available. The training is currently slated to begin sometime this summer, and the Alliance contends that providers, technology vendors and other stakeholders will need more time to get up to speed before an effective transition could occur.

The Alliance supports a proposal that would allow a physician member of the hospice team to determine admission to care, in addition to the medical director or a designee. CMS and the Alliance agreed that this would establish greater consistency between different components of hospice regulations and policies.

However, the Alliance took issue with a proposed new requirement for a “clearly titled” physician or nurse practitioner face-to-face encounter attestation that must include a signature and dates of signing. This would be separate from the recertification form.

“While the Alliance understands the need for a face-to-face requirement for hospice patients in their third benefit period or later, we are concerned about the proposal that the ‘[face-to-face] attestation, its accompanying signature, and the date signed, must be a separate and distinct section of, or an addendum to, the recertification form, and must be clearly titled,’” the Alliance said. “The current audit environment already places considerable pressure on hospices, and the proposed formatting requirements risks creating inadvertent compliance pitfalls.”