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Hospice Billing Services

Hospice is paid a flat per-diem for every day a patient is enrolled -- but only if the Notice of Election is filed within five calendar days, the level of care is coded correctly, the face-to-face encounter is on file before the third benefit period, and the aggregate cap holds. MedPrecision manages that entire cycle for the Medicare hospice benefit and every payer behind it.

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Quick Answer

What Are Hospice Billing Services?

Hospice billing services convert enrolled hospice days into paid claims under the Medicare hospice benefit, which pays a fixed per-diem rate for each day a beneficiary is enrolled regardless of the services provided that day. To elect the benefit, a patient must be entitled to Medicare Part A and certified as terminally ill (42 CFR 418.20), which requires a physician's certification that the prognosis is a life expectancy of six months or less if the illness runs its normal course (42 CFR 418.22). Billing spans four levels of care -- Routine Home Care, Continuous Home Care, Inpatient Respite Care, and General Inpatient Care -- each with its own daily rate, plus a Notice of Election that must be filed within five calendar days after the election effective date (42 CFR 418.24), benefit-period and face-to-face tracking, Service Intensity Add-on capture, and monitoring of the per-beneficiary aggregate cap. That cap is $35,361.44 for the FY 2026 cap year (1 October 2025 through 30 September 2026) and $36,174.75 for the FY 2027 cap year beginning 1 October 2026 (CMS MLN Matters MM14557).

  • Per-diem billing across four levels of care (RHC, CHC, IRC, GIP), each with its own daily rate
  • Notice of Election filed inside the 5-calendar-day window and acceptance confirmed, not assumed
  • Benefit-period (90-90-60) and physician face-to-face tracking before the third and later periods
  • Aggregate cap ($35,361.44 for FY 2026; $36,174.75 from 1 October 2026) and the 20% inpatient cap monitored through the year
$236.33/day
FY 2027 Routine Home Care Rate (days 1-60)
Base RHC daily per-diem for hospices submitting required quality data, before wage-index adjustment; days 61+ are $186.33. Applies to services from 1 October 2026 through 30 September 2027; the FY 2026 rates were $230.83 and $181.94 (CMS Transmittals 13976 and 13331)
$36,174.75
FY 2027 Aggregate Cap per Beneficiary
FY 2027 cap year (1 October 2026 through 30 September 2027) limit on average payment per beneficiary: the FY 2026 cap of $35,361.44 increased by the 2.3% FY 2027 payment update (CMS FY 2027 hospice final rule, CMS-1851-F)
5 calendar days
Notice of Election Filing Window
42 CFR 418.24 requires the NOE to be filed within 5 calendar days after the election effective date; days from that date to the date of filing are non-covered, provider-liable days the hospice may not bill the beneficiary for, reported with occurrence span code 77
2.3%
FY 2027 Hospice Payment Update
3.2% inpatient hospital market basket minus a 0.9-point productivity adjustment, effective 1 October 2026; hospices that miss the quality reporting requirements receive -1.7% instead. The FY 2026 update was 2.6% (CMS MLN Matters MM14557 and MM14190)
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Hospice billing services are a distinct discipline inside revenue cycle management, governed by a per-diem payment model and a filing calendar that no other Medicare provider type faces. When a beneficiary elects the Medicare hospice benefit they agree to forgo curative treatment for the terminal condition, and CMS pays the hospice a daily rate for each day the patient is enrolled regardless of the number of services provided that day -- including days on which the hospice provides no services at all. That single structural fact reshapes everything downstream: the Notice of Election must be filed with the Medicare contractor within five calendar days after the effective date of the election statement (42 CFR 418.24), four levels of care each carry their own daily rate, benefit periods have to be tracked across 90-90-60 cycles with a physician or nurse-practitioner face-to-face encounter before the third period (42 CFR 418.22), and an aggregate cap can claw back payment at year-end. MedPrecision's hospice billing services team manages that full cycle for freestanding, hospital-based, and facility-based hospice agencies -- filing elections and revocations, coding each day to the right level of care, capturing the Service Intensity Add-on, projecting both the aggregate and inpatient caps, and working the NOE, medical-necessity, and recertification denials that quietly turn covered days into provider liability. The rates below carry their fiscal year because they change every 1 October: FY 2026 rates apply to services through 30 September 2026 (CMS MLN Matters MM14190) and FY 2027 rates apply from 1 October 2026 (CMS MLN Matters MM14557).

Who This Service Is For

Freestanding for-profit and nonprofit hospice agencies billing the Medicare hospice benefit Hospital-based and health-system hospice programs that also manage General Inpatient Care days Facility-based hospice serving patients in skilled nursing, assisted living, and nursing homes (Q5002-Q5004 site-of-service coding) Home health agencies expanding into hospice or running combined home-health-and-hospice (HHH) operations

The State of Hospice Billing Services in 2026

Hospice sits in a payment framework built specifically for end-of-life care, and every figure in it carries a fiscal year because the whole table is replaced each 1 October. Under the Medicare hospice benefit, four levels of care are each paid a per-diem set by CMS. For FY 2026 -- services through 30 September 2026 -- Routine Home Care is $230.83 per day for days 1-60 and $181.94 for days 61+, Continuous Home Care is $1,674.29 for a full 24-hour day ($69.76 per hour), Inpatient Respite Care is $532.48 per day and General Inpatient Care is $1,199.86 per day. For FY 2027, effective 1 October 2026, those become $236.33 and $186.33, $1,726.16 ($71.92 per hour), $545.93 and $1,231.51 respectively (CMS Transmittal 13331, CMS Transmittal 13976). Those rates are wage-adjusted by the hospice wage index (the pre-floor, pre-reclassified IPPS hospital wage index for the patient's location), with a permanent 5% cap since FY 2023 preventing any area's index from falling below 95% of its prior-year value, and labor shares that differ by level (66% RHC, 75.2% CHC, 61% IRC, 63.5% GIP). The FY 2026 update was 2.6%, an estimated increase of $750 million in payments (CMS FY 2026 hospice final rule fact sheet); the FY 2027 update is 2.3%, an estimated increase of $755 million (CMS FY 2027 hospice final rule fact sheet). Because payment is a flat daily rate, revenue is won or lost on timing and documentation -- the NOE clock, the recertification calendar, and the aggregate and 20% inpatient caps -- not on coding intensity. What this page does not publish is a count of Medicare-certified hospices or a for-profit share: those circulate widely in rule summaries, but we could not confirm them against a CMS file, and a number we cannot re-derive does not belong next to ones we can.

What Is Breaking Right Now

Non-covered, provider-liable days because the Notice of Election missed the 5-calendar-day window and had to be reported with occurrence span code 77

Recertification denials because the physician or nurse-practitioner face-to-face encounter was not performed or attested before the third benefit period

Year-end aggregate-cap liability that surfaces too late to manage the census or admissions mix

General Inpatient and Inpatient Respite days billed beyond the 20% inpatient cap, which is reconciled against the hospice at the end of the cap year

Missed Service Intensity Add-on revenue on RN and social-worker visits in the last seven days of life, and RHC days billed at the day-1-60 rate past day 60

Common Hospice Billing Services Mistakes to Avoid

Filing the Notice of Election after the 5-calendar-day window

Every day from the election effective date to the date the NOE is filed becomes non-covered and provider-liable, has to be reported with occurrence span code 77, and cannot be billed to the beneficiary -- unpaid days for care the hospice already delivered.

Treat the NOE as the first billing action after admission, not a back-office task. File it as Type of Bill 8xA and confirm MAC acceptance well inside the window, so an election effective 10/10 is accepted by 10/15, not 10/16 -- and remember the window counts calendar days, so a Friday admission is not a Monday problem.

Missing the physician face-to-face encounter before the third benefit period

Without a timely, signed, and dated face-to-face encounter, the recertification is not supportable and the benefit period denies -- even when the patient remains clinically eligible.

Track the benefit-period calendar and schedule the physician or NP encounter inside the 30-day pre-recert window, capturing the signed and dated attestation 42 CFR 418.22 requires -- a clinical note qualifies only if it also records the clinical findings, the date of the visit and the date of the signature.

Ignoring the aggregate cap until year-end reconciliation

A hospice whose average payment per beneficiary exceeds the cap -- $35,361.44 for FY 2026, $36,174.75 for FY 2027 -- must repay Medicare the difference, and by the time the cap year closes there is nothing left to adjust: the overage is already owed.

Project the aggregate cap continuously against census and length of stay, and monitor the 20% inpatient cap on GIP plus IRC days, so admissions mix and inpatient utilization are managed before the limits are breached.

Leaving the Service Intensity Add-on and RHC rate tiers uncaptured

RN and social-worker visits in the last seven days of life go unbilled, and RHC days keep billing at the day-1-60 rate past day 60 -- real per-diem revenue and add-on payments simply never make it onto the claim.

Build SIA identification into end-of-life billing at the CHC hourly rate, from 15 minutes up to four hours per day, and code each RHC day to the correct day-1-60 versus day-61+ tier automatically as length of stay accrues.

What We Handle

Eligibility, Part A & Certification of Terminal Illness

We verify Medicare Part A entitlement and confirm the physician certification of terminal illness -- a prognosis of six months or less if the illness runs its normal course, per 42 CFR 418.20 and 418.22 -- and set up the election so claims for conditions unrelated to the terminal illness still route to Medicare rather than being absorbed into the hospice per-diem.

Notice of Election & Revocation Filing

MedPrecision files the Notice of Election as Type of Bill 8xA and confirms the MAC accepted it, rather than treating submission as the finish line; we also file the Notice of Termination/Revocation when a patient revokes or is discharged. Because 42 CFR 418.24 counts calendar days, not business days, a Friday or holiday admission still has to be worked -- elections are picked up from your census every day the hospice admits, not only on weekdays. When the NOE is late, Medicare will not cover or pay the days from the election effective date to the date of filing; those days are a provider liability, the hospice may not bill the beneficiary for them, and they are reported with occurrence span code 77.

Benefit-Period & Face-to-Face Tracking

We track the 90-90-60 benefit-period sequence (two 90-day periods followed by unlimited 60-day periods) and schedule the physician or nurse-practitioner face-to-face encounter required for any patient whose total stay across all hospices is anticipated to reach the third benefit period, and for every period after that. Per 42 CFR 418.22 the encounter must occur no more than 30 calendar days before the recertification, and the attestation must carry the clinician's signature and the date it was signed.

Four-Level-of-Care Coding & Site-of-Service Q-codes

Each day is coded to the correct level -- Routine Home Care, Continuous Home Care, Inpatient Respite Care, or General Inpatient Care -- on its own revenue code (651, 652, 655, 656), with the correct RHC day-1-60 versus day-61+ tier and the HCPCS Q5001-Q5010 site-of-service code that reports where care was delivered (home, assisted living, SNF, inpatient hospital, or hospice facility).

Service Intensity Add-on (SIA) Capture

We identify registered-nurse and social-worker visits during the last seven days of a patient's life and bill the Service Intensity Add-on on Routine Home Care days at the Continuous Home Care hourly rate times the direct care provided, from a minimum of 15 minutes up to four hours per day. The CHC hourly rate is $69.76 for FY 2026 and $71.92 from 1 October 2026 -- end-of-life revenue that is routinely left uncaptured.

Aggregate & Inpatient Cap Monitoring

We monitor the per-beneficiary aggregate cap -- $35,361.44 for the FY 2026 cap year and $36,174.75 for the FY 2027 cap year starting 1 October 2026, neither adjusted for geographic wage differences -- and the separate inpatient cap that limits General Inpatient plus Inpatient Respite days to no more than 20% of total patient-care days, projecting overages through the year instead of discovering them at reconciliation when the difference must be repaid to Medicare.

Denial Management, Appeals & HQRP Support

We work NOE, medical-necessity, and recertification denials by root cause, appeal provider-liable determinations where the documentation supports it, and keep Hospice Quality Reporting Program submissions (the HIS/HOPE assessment and CAHPS Hospice Survey) current -- because a hospice that does not meet the quality reporting requirements takes a four percentage-point cut to the annual update, turning the 2.6% FY 2026 increase into -1.4% and the 2.3% FY 2027 increase into -1.7%.

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Stop Losing Days to the NOE Clock

Send us a sample of your provider-liable days, late NOEs, and recertification denials. We will show you which were preventable timing failures, where the aggregate or inpatient cap is trending toward repayment, and what a clean hospice billing cycle should protect -- and scope the engagement against your census and level-of-care mix before any rate is quoted.

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Our Hospice Billing Services Methodology

01

NOE-First Filing Discipline

The Notice of Election is the first billing action after admission. We file it as Type of Bill 8xA and confirm MAC acceptance inside the five-calendar-day window, because a late NOE converts every day from the election effective date to the date of filing into a non-covered, provider-liable loss reported with occurrence span code 77. The window counts calendar days, so elections are pulled from your census every day you admit; an election still unaccepted on day three escalates to your named account lead. This single control protects more revenue than any coding refinement can.

02

Benefit-Period & Recertification Control

We track the 90-90-60 benefit-period sequence and schedule the physician or nurse-practitioner face-to-face encounter before the third and every subsequent period, inside the 30-day pre-recert window. The signed and dated attestation 42 CFR 418.22 requires is confirmed in the record before the recertification is billed, so eligible patients are never denied for a missing encounter.

03

Level-of-Care Accuracy & SIA Capture

Each day is coded to the correct level -- RHC, CHC, IRC, or GIP -- on its revenue code and, for RHC, the correct day-1-60 versus day-61+ tier. We capture the Service Intensity Add-on on RN and social-worker visits in the last seven days of life at the Continuous Home Care hourly rate, from 15 minutes up to four hours per day, so end-of-life care that was delivered is also billed.

04

Dual-Cap Monitoring

We project both caps through the year: the per-beneficiary aggregate cap ($35,361.44 for FY 2026 and $36,174.75 for FY 2027, neither wage-adjusted) and the inpatient cap that holds GIP plus IRC days to 20% of total patient-care days. Because overages are unrecoverable once delivered, monitoring is continuous rather than a year-end reconciliation exercise, and a projection crossing its limit escalates the day it is flagged.

05

Quality-Reporting & Denial Integrity

Hospice Quality Reporting Program submissions (the HIS/HOPE patient assessment and the CAHPS Hospice Survey) are kept current so the annual update is not cut by four percentage points -- the difference between 2.6% and -1.4% in FY 2026, and between 2.3% and -1.7% in FY 2027. NOE, medical-necessity, and recertification denials are worked by root cause and appealed where the documentation supports it, and the pattern is fed back into pre-bill review.

Side by Side

Hospice Billing Services: MedPrecision vs Alternatives

Feature MedPrecision In-House Other Providers
Notice of Election Timeliness NOE filed as TOB 8xA inside the 5-calendar-day window and tracked to MAC acceptance, with provider-liable exposure flagged before it happens and weekend admissions worked the same as weekday ones NOE treated as paperwork; late filings discovered only when days deny with occurrence span code 77 NOE submitted but acceptance not confirmed, so late/rejected elections surface downstream
Benefit-Period & Face-to-Face Tracking 90-90-60 calendar tracked with the physician/NP encounter scheduled inside the 30-day pre-recert window and a signed, dated attestation on file Recertifications tracked manually; missed encounters cause avoidable benefit-period denials Basic recert reminders without face-to-face attestation control
Level-of-Care Coding & SIA Each day coded to RHC/CHC/IRC/GIP on the right revenue code and RHC tier, with SIA captured on last-7-days visits Levels coded but RHC day-61 tier drops and SIA add-ons frequently missed Level-of-care coding with limited SIA or tiered-rate capture
Cap Management Aggregate cap ($35,361.44 FY 2026, $36,174.75 FY 2027) and the 20% inpatient cap projected through the year, not at reconciliation Caps reviewed after the cap year, when overages are already owed to Medicare Cap reporting provided but not actively projected or managed
Compliance & Quality Reporting HQRP submissions (HIS/HOPE and CAHPS Hospice Survey) kept current so the annual update is not cut by four percentage points Quality reporting handled separately from billing, risking the four-point penalty update (-1.4% in FY 2026, -1.7% in FY 2027) General compliance not tied to the hospice quality-reporting penalty

How the Transition Works

How we deliver hospice billing services for your practice.

1

Election & Eligibility Setup

We confirm Medicare Part A entitlement and the physician certification of terminal illness, build the election record and the first benefit period, and identify which conditions are related to the terminal illness (paid under the per-diem) versus unrelated (still billable to Medicare). The handoff is defined at onboarding rather than left to habit: the hospice sends a daily census of admissions, discharges, revocations and transfers, plus the signed election statement, the certification of terminal illness and, where applicable, the face-to-face attestation. We work inside your existing hospice EMR and your MAC's claim system rather than requiring a platform change; the specific systems, access and daily cut-off are named in the service agreement.

2

NOE Filing & Level-of-Care Coding

The Notice of Election is filed as Type of Bill 8xA inside the five-calendar-day window and tracked until the MAC accepts it, each day is coded to its level of care and revenue code with the correct RHC tier and Q5001-Q5010 site of service, and Service Intensity Add-on visits are captured on end-of-life days. Anything missing from the census handoff -- an unsigned election, an absent certification, visit detail that has not posted -- is queried back the same day with the specific missing element named.

3

Recertification & Face-to-Face Control

We track the benefit-period calendar, schedule the physician or nurse-practitioner face-to-face encounter before the third and every subsequent period, and confirm the signed, dated attestation is in the record -- which under 42 CFR 418.22 may be a clinical note, provided it records that the encounter occurred, the clinical findings, the date of the visit, the clinician's signature and the date of that signature -- so recertifications are not denied for a missing encounter.

4

Posting, Cap Monitoring & Denials

Per-diem remittances are posted at the line level, the aggregate and 20% inpatient caps are projected as days accrue, and NOE, medical-necessity, and recertification denials are worked by root cause and appealed rather than written off to provider liability. Escalation is on a clock rather than on judgement: an election still unaccepted on day three of the five-day window, a recertification inside 10 days of the period start with no attestation on file, and a cap projection crossing its limit all go to your named account lead the day they are flagged, with the hospice's administrator copied.

What Reporting and Visibility Looks Like

Transparency is built into every engagement. You will always know where your revenue stands and what actions are being taken on your behalf.

Monthly KPI Dashboards

Track collection rates, denial trends, days in A/R, and payer-level performance with dashboards delivered on a fixed schedule.

Real-Time Claim Tracking

See claim status updates in real time so you never have to wonder where a payment stands or when follow-up is happening.

Quarterly Business Reviews

Detailed reviews with actionable recommendations covering denial root causes, payer trends, and revenue recovery opportunities.

Proactive Alerts

Automated alerts when key metrics shift, so issues are caught and addressed before they affect your bottom line.

Glossary

Hospice Billing Services Key Terms

Medicare Hospice Benefit
The Part A benefit under which a terminally ill beneficiary elects comfort-focused care and forgoes curative treatment for the terminal condition. The hospice is paid a predetermined per-diem for each enrolled day regardless of services provided, while Medicare continues to cover items and services for conditions unrelated to the terminal illness.
Notice of Election (NOE)
The election notice, submitted like a claim as Type of Bill 8xA, that 42 CFR 418.24 requires the hospice to file with its Medicare contractor within five calendar days after the effective date of the election statement. A late NOE makes the days from the election effective date to the date of filing non-covered and provider-liable; the hospice may not bill the beneficiary for them and reports them with occurrence span code 77.
Four Levels of Care
The four per-diem categories distinguished by location and intensity: Routine Home Care (RHC, the default level for any day the patient is at home and not in crisis), Continuous Home Care (CHC, hourly, for an in-home crisis, eight or more predominantly nursing hours in a day), Inpatient Respite Care (IRC, up to five consecutive days at a time) and General Inpatient Care (GIP, for symptoms unmanageable elsewhere), reported on revenue codes 651, 652, 655 and 656.
Hospice Aggregate Cap
The annual per-beneficiary limit on average hospice payment -- $35,361.44 for the FY 2026 cap year and $36,174.75 for FY 2027 -- above which a hospice must repay Medicare the difference. It is not adjusted for geographic wage differences, and for accounting years ending after 30 September 2016 and before 1 October 2035 it is updated by the hospice payment update percentage rather than by the Consumer Price Index for All Urban Consumers.
Service Intensity Add-on (SIA)
An add-on paid on Routine Home Care days for registered-nurse or social-worker visits during the last seven days of a beneficiary's life, equal to the Continuous Home Care hourly rate times the direct care provided, from a minimum of 15 minutes up to four hours per day. The CHC hourly rate is $69.76 for FY 2026 and $71.92 for FY 2027.

Common Questions

Common questions about hospice billing services.

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How does Medicare pay for hospice, and what do hospice billing services actually do?

Medicare pays hospice a daily rate for each day a beneficiary is enrolled, regardless of how many visits or services are delivered that day -- including days on which no services are provided. Hospice billing services manage the mechanics that make those per-diems payable: verifying Part A entitlement and the physician certification of terminal illness, filing the Notice of Election within five calendar days (42 CFR 418.24), coding each day to the right level of care and revenue code, capturing the Service Intensity Add-on, tracking benefit periods and the face-to-face encounter, and monitoring the aggregate and inpatient caps. Because the payment is a flat daily rate, the revenue risk is almost entirely on the compliance side -- a late election or a missing recertification does more damage than an undercoded visit ever could. Scope and price are set per engagement rather than from a rate card: the drivers are average daily census, the mix of levels of care (General Inpatient and Continuous Home Care carry far more documentation than Routine Home Care), the number of MAC jurisdictions and non-Medicare payers in play, and whether cap projection and denial appeals are in scope. The rate and what it covers are stated in the service agreement before any claim is touched.

What is the Notice of Election, and what happens if it is filed late?

The Notice of Election (NOE) tells Medicare that a beneficiary has elected the hospice benefit. It is submitted like a claim, as Type of Bill 8xA. Under 42 CFR 418.24, the hospice must file it with its Medicare contractor within five calendar days after the effective date of the election statement -- so an election effective 10/10 is due by 10/15. The regulation measures filing, but a MAC returns an NOE that fails its edits and a returned NOE is not a filed one, which is why we track every election through to acceptance rather than stopping at submission. When the NOE is late, Medicare will not cover or pay for days of hospice care from the effective date of election to the date the NOE is filed; those days are a provider liability, the hospice may not bill the beneficiary for them, and they are reported on the claim with occurrence span code 77 as non-covered. CMS may waive that consequence where it determines the hospice's circumstance was exceptional, but the hospice must fully document the circumstance and furnish whatever CMS requests. Filing every election inside the window is the single highest-value control in hospice billing, and because the window runs in calendar days it has to be worked on weekends and holidays too.

What are the four levels of hospice care and their current rates?

The hospice payment system has four levels distinguished by location and intensity, each reported on its own revenue code (651, 652, 655, 656). Routine Home Care (RHC) is the default level -- any day the patient is at home and not in crisis, where home may be a private residence, an assisted living facility or a skilled nursing facility. Continuous Home Care (CHC) is billed only during a crisis in the home and requires eight or more hours of care in a day, predominantly nursing; the eight hours do not have to be continuous, and below eight hours the day reverts to RHC. Inpatient Respite Care (IRC) gives an informal caregiver a break in an approved inpatient facility for up to five consecutive days at a time. General Inpatient Care (GIP) manages pain or symptoms that cannot be managed in another setting. The national rates before wage-index adjustment, for hospices that submit the required quality data, are: for FY 2027 (services from 1 October 2026) RHC $236.33 per day for days 1-60 and $186.33 for days 61+, CHC $1,726.16 for 24 hours at $71.92 per hour, IRC $545.93 and GIP $1,231.51; and for FY 2026 (services through 30 September 2026) RHC $230.83 and $181.94, CHC $1,674.29 for a full 24 hours (a $69.76 hourly rate, per the FY 2026 hospice final rule), IRC $532.48 per day and GIP $1,199.86 per day. The FY 2027 table is published in CMS Transmittal 13976, issued 30 September 2026 to replace Transmittal 13924 after CMS corrected the FY 2027 hospice wage index, and the FY 2026 table in CMS Transmittal 13331. Hospices that do not meet the quality reporting requirements are paid from a separate, lower table.

How does the hospice aggregate cap work, and is there a separate inpatient cap?

There are two caps. The aggregate cap limits average payment per beneficiary: it is $35,361.44 for the FY 2026 cap year (1 October 2025 through 30 September 2026) and $36,174.75 for the FY 2027 cap year, which is the FY 2026 amount increased by the 2.3% FY 2027 payment update (CMS FY 2027 hospice final rule fact sheet). A hospice whose total payments exceed the cap must repay Medicare the difference. Unlike the daily rates, the cap is not adjusted for geographic wage differences. For accounting years ending after 30 September 2016 and before 1 October 2035, the cap is updated by the hospice payment update percentage rather than by the Consumer Price Index for All Urban Consumers -- an extension most recently made by section 6218 of the Consolidated Appropriations Act, 2026 (CMS MLN Matters MM14557). Separately, an inpatient cap limits a hospice's General Inpatient plus Inpatient Respite days to no more than 20% of its total patient-care days, and days above that limit are reconciled against the hospice at the end of the cap year. Both caps have to be projected during the year, not reconciled after it, because there is no way to recover the overage once the days are delivered.

When is the physician face-to-face encounter required for recertification?

A hospice physician or hospice nurse practitioner must have a face-to-face encounter with each hospice patient whose total stay across all hospices is anticipated to reach the third benefit period, and before every benefit period after that. Per 42 CFR 418.22 the encounter must occur prior to, but no more than 30 calendar days prior to, that recertification. This has applied since 1 January 2011. The attestation must include the physician's or nurse practitioner's signature and the date it was signed, and it may be a separate section of the recertification, an addendum to it, or a clinical note -- provided the note records that the encounter occurred, the clinical findings, the date of the visit, the signature of the clinician who conducted the encounter and the date of that signature. The narrative for the third and every subsequent recertification must also explain why those clinical findings support a life expectancy of six months or less. A missed, unsigned or undated encounter is a recurring cause of recertification denials on otherwise eligible patients.

What is the Service Intensity Add-on (SIA), and why is it often missed?

The Service Intensity Add-on pays an add-on on top of the Routine Home Care per-diem for registered-nurse or social-worker visits during the last seven days of a beneficiary's life. It equals the Continuous Home Care hourly rate multiplied by the direct patient care provided, from a minimum of 15 minutes up to a maximum of four hours per day -- $69.76 per hour for FY 2026 and $71.92 per hour from 1 October 2026. It is easy to miss because it depends on correctly identifying the last seven days of life and pulling the visit detail for RN and social-worker time on RHC days -- data that lives in the clinical record, not the claim header. Capturing it is real, sourced revenue for care the hospice already delivered, so we build SIA identification into end-of-life billing rather than treating it as an afterthought.

How does Medicare pay for hospice care?

Medicare pays hospice a flat per-diem for each day a beneficiary is enrolled, set by the level of care delivered rather than the number of visits. There are four levels, each with its own national rate before wage-index adjustment. For FY 2026 -- services through 30 September 2026 -- Routine Home Care pays $230.83 per day for days 1-60 and $181.94 for days 61 and later, Continuous Home Care pays $1,674.29 for a full 24 hours ($69.76 per hour in the FY 2026 hospice final rule), Inpatient Respite Care $532.48 per day and General Inpatient Care $1,199.86 per day (CMS Transmittal 13331); the FY 2026 update was 2.6%, being the 3.3% inpatient hospital market basket increase less a 0.7 percentage-point productivity adjustment (CMS MLN Matters MM14190). For FY 2027 -- services from 1 October 2026 -- the rates are $236.33 and $186.33 for RHC, $1,726.16 for a 24-hour CHC day ($71.92 per hour), $545.93 for IRC and $1,231.51 for GIP (CMS Transmittal 13976), under a 2.3% update built from a 3.2% market basket increase less a 0.9 percentage-point productivity adjustment (CMS MLN Matters MM14557). Rates change every 1 October, so confirm the fiscal year before quoting any of them.

What is the hospice Notice of Election (NOE) 5-day filing rule and its penalty?

Under 42 CFR 418.24 the hospice must file the Notice of Election with its Medicare contractor within five calendar days after the effective date of the election statement -- so an election effective 10/10 has an NOE due by 10/15. When it is filed late, Medicare will not cover or pay for any day from the election effective date through the date the NOE is filed. Those days are a provider liability: the hospice cannot bill the beneficiary for them and must report them with occurrence span code 77 as non-covered, or the claim is returned. CMS may waive that consequence where it determines the circumstance the hospice encountered was exceptional, but the hospice has to document it fully and supply whatever CMS asks for. In practice the operative deadline is tighter than the regulation reads, because a MAC returns an NOE that fails its edits and a returned NOE has not been filed -- so the control is filing early enough to absorb one rejection.

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Stop Losing Days to the NOE Clock

Send us a sample of your provider-liable days, late NOEs, and recertification denials. We will show you which were preventable timing failures, where the aggregate or inpatient cap is trending toward repayment, and what a clean hospice billing cycle should protect -- and scope the engagement against your census and level-of-care mix before any rate is quoted.

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