Now there is a wrinkle in that October 1 effective date that hospice leaders need to know about, but I want to be very careful about how we talk about it because I do not want agencies stopping their preparations.
On August 20, 2026, the U.S. Government Accountability Office reviewed the FY 2027 Hospice Final Rule and determined that CMS did not provide the 60-day delay required for a major rule under the Congressional Review Act. The final rule was published August 3, Congress received it August 5, and CMS established an effective date of October 1. According to GAO, that timeline does not provide the required 60-day delay.
That does not mean the final rule has been overturned, and it does not mean CMS has officially delayed the October 1 implementation date. As of now, CMS’s published effective date remains October 1. Until CMS tells us differently, I think hospices should continue preparing for that date exactly as planned.
If CMS ultimately gives agencies a little more time because of the issue GAO identified, great. Use the additional time to tighten your processes even further. But I would much rather see an agency completely prepared for October 1 and receive a little extra time than stop preparing now and find itself scrambling later.
September Is the Month to Get This Right
We have September to make sure this process is built into the admission workflow and that everyone responsible for completing the addendum understands exactly what is expected.
This isn’t something I would introduce to the admission team on September 30. There are workflow decisions to make, staff to educate, forms and EMRs to address, and some basic hospice coverage concepts that I would make sure everyone understands before they’re responsible for explaining this document to patients and families.
There are three things I would be working on right now.
1. Build Your Process
The first thing leadership needs to determine is exactly how this is going to work operationally. Beginning with the scheduled implementation, the addendum becomes part of the election process for every Medicare beneficiary electing hospice, not just the patients who have something the hospice identifies as non-covered.
That means your team needs a reliable workflow that doesn’t depend on someone remembering that a particular patient needs the form. Build it into your standard admission process so it happens consistently.
I would make sure you’ve clearly established:
- Who is responsible for completing the addendum.
- At what point during the admission process it will be completed.
- How the hospice will ensure the form isn’t missed.
- How completed forms will be incorporated into the medical record.
- How the patient or representative will receive a copy.
- What your process will be when an electronic signature isn’t appropriate or available.
The important part is consistency. If this is going to apply to every Medicare hospice election, it needs to become part of the normal admission workflow rather than an extra form someone has to remember.
2. Educate Your Team About What Is Covered and What Isn’t
This may actually be the part I would spend the most time on.
Please don’t assume that everyone completing hospice admissions understands the difference between services, medications, items, and conditions that are related to the terminal illness and related conditions and those that are truly unrelated.
There is still a tremendous amount of confusion around hospice coverage. If the person completing the addendum doesn’t understand what Medicare expects hospice to cover, we have a much bigger problem than whether the form itself was filled out correctly.
This is a great time to go back to the basics with your admission nurses and anyone else responsible for completing or explaining this information. Make sure they understand what hospice is responsible for covering and how determinations about unrelated items, services, and drugs are made. They also need to be able to explain that information clearly to a patient or family without making the process unnecessarily confusing.
The form is only as accurate as the person completing it.
3. Make Sure Everyone Understands the Signature and Copy Requirements
Your team also needs to understand what happens after the addendum is completed. The patient or representative needs to receive the information, and the addendum includes acknowledgment of receipt. Your staff needs a clear process for obtaining and documenting that acknowledgment and ensuring the appropriate copy is maintained in the hospice record.
If your organization uses electronic signatures, make sure your workflow also accounts for patients and representatives who cannot or do not want to use an electronic process. Don’t build a system that works beautifully when everyone has email, technology, and the ability to electronically sign but falls apart the minute someone doesn’t.
Admission staff should know exactly what to do in each situation, including what to do when a patient or representative refuses to sign. This is the kind of thing that should be worked out in policy and education now rather than decided at the bedside after implementation.
Don’t Let the GAO Finding Slow Down Your Preparation
The GAO finding is important, and hospice leaders should absolutely be watching for additional direction from CMS. There could be a clarification, correction notice, or change involving the effective date. If CMS changes the timeline, we’ll adjust.
For now, October 1 remains the date hospices should be preparing for. Use September to educate your team, test your workflow, make sure your forms and systems are ready, and identify the problems before you’re doing this with an actual admission sitting in front of you.
If CMS gives us additional time, consider it a bonus. Use it to make the process even better. But don’t gamble your compliance program on a delay that CMS has not announced.
The goal should be simple: when this requirement becomes effective, whether that remains October 1 or CMS ultimately makes an adjustment, your team shouldn’t be trying to figure out what to do. They should already know.
At The Amity Group, we work with hospice agencies across the country on compliance, documentation, auditing, and the operational issues that come with regulatory changes like this one. We will also continue watching the GAO issue and any subsequent CMS action closely because if the effective date changes, hospices need to know quickly.
