CMS Plans Advance Care Planning Quality Measure

The U.S. Centers for Medicare & Medicaid Services (CMS) has proposed an advance care planning quality measure for several health care settings, a move that could boost hospice utilization.

The measure, designated MUC202-020, would link reimbursement to whether patients have documented end-of-life conversations. If finalized it would require tracking of advance care planning documentation for patients 18 or older, with an emphasis on those with inpatient stays. It would apply to hospitals, home health, skilled nursing facilities and ambulatory surgery centers, according to CMS. The proposed measure would also be included in the Merit-Based Incentive Payment System (MIPS).

If finalized, the quality measure could result in significant savings for the health care system, according to Tatiania Fofanova, CEO of the advance care planning technology company Koda Health.

“The cost on the American taxpayer is continuing to rise. It’s even larger when you take into account seriously ill populations in general, because we don’t want to intervene only at the end of life,” Fofanova told Hospice News. “We want to intervene and guide the trajectory of care far earlier on, so that we can make sure that patient preferences and the care they receive are aligned years and years before they get to that end of life event. And so the financial impact is pretty significant.”

Only about 36% of U.S. adults have documented their end-of-life wishes, research has shown. This often means that they receive more aggressive care than they would have preferred had they known their options and documented their choices.

Advance care planning is also associated with increased hospice utilization, according to a 2025 study published in the journal JCO Oncology Practice.

“There’s a big problem to solve. Something like $200 billion a year is spent on care that patients say they wouldn’t want. So there’s a real Delta there,” Bryan Sivak, founder and managing partner of the venture capital firm Evidenced, told Hospice News. “If we’re looking at ways to save money across the board in health care, which everybody is, this is like a no-brainer for me as a place to start.”

Sivak is an investor in Koda Health and the former chief technology officer for CMS.

Fofanova co-founded Koda Health in 2020 with Chief Medical Officer Dr. Desh Mohan and Katelin Cherry, the company’s chief technology officer. The three met and began collaborating at the Texas Medical Center’s (TMCi) Biodesign program, which tasked them with finding solutions to problems affecting the health system. Koda Health spun out of that work as an independent company.

To be effective, providers reporting on the measure must ensure they have a high-quality advance care planning process, rather than just “checking a box,” according to Mohan. 

A high-quality process would document the patient’s values, their quality of life preferences, designate a surrogate decision maker and ensure a “continuum of understanding” of the individual’s goals, Mohan said.

“The [quality measure] requirements would be whether there’s documentation in the electronic health record of advanced care planning taking place. The requirements of what that looks like have not been fully defined or shared,” Mohan told Hospice News. “That’s going to be an important consideration going forward to make sure that this is not just a check-box measure. Those kinds of check box approaches often are not effective, and making sure this is a high-quality planning process is really important.”

The National Partnership for Healthcare and Hospice Innovation has endorsed the proposed measure.

The National Alliance for Care at Home voiced support for the spirit of the measure but raised questions about how it would be implemented.

“The measure under consideration would not be applicable to the Hospice Quality Reporting Program, despite ACP being fundamental to high-quality hospice care,” the Alliance indicated in a statement. “Of note, while physicians and qualified health care practitioners are able to receive payment for advance care planning discussions, there is no payment mechanism for ACP conversations completed by home health agencies, leaving them without appropriate compensation for this vital patient service in contrast to other settings where this MUC would also be applicable.”