Advance Care Planning Measure Raises Concerns for Home Health Agencies

A proposed quality measure from the Centers for Medicare & Medicaid Services would require providers to document advance care planning conversations with patients and incorporate the reporting into several federal quality programs.

The proposal would apply across multiple care settings, including hospitals, skilled nursing facilities, ambulatory surgery centers, and home health agencies. CMS also intends to incorporate the measure into the Merit-Based Incentive Payment System (MIPS), linking compliance to reimbursement incentives and penalties.

Advance care planning discussions—conversations about patient goals, treatment preferences, and end-of-life decisions—are widely viewed as a cornerstone of patient-centered care. Many industry groups support the intent of encouraging these conversations earlier in the care continuum.

However, home health advocates say the proposal raises practical concerns for agencies delivering care in patients’ homes. Unlike physicians and certain other clinicians, home health agencies currently do not have a direct reimbursement pathway for advance care planning services.

Without a payment mechanism, agencies could face new expectations to document and report these conversations as part of federal quality reporting programs while absorbing the administrative cost of doing so.

Advocates warn the result could effectively create an unfunded federal requirement, particularly challenging for agencies already navigating complex regulatory and reporting frameworks.

The proposal arrives as federal policymakers continue searching for ways to align care with patient preferences, reduce unnecessary hospitalizations, and manage spending in the final months of life.

CMS Updates Hospice Policy Guidance

Separately, CMS released Transmittal 13664 / Change Request (CR) 14384, updating Chapter 9 of the Medicare Benefit Policy Manual related to hospice coverage and operations.

The revisions incorporate policy changes finalized in the FY 2026 Hospice Final Rule and clarify several areas of hospice administration.

Key updates include:

Certification Requirements
CMS added new language to Section 20.1 addressing the timing and content of hospice certification, aligning manual guidance with updated certification attestation requirements introduced in the FY 2026 rule. These revisions build on earlier policy guidance released in Transmittal 13503 / CR 14272.

Hospice Transfers
Section 20.2.1 was revised to clarify that when a patient transfers from one hospice provider to another, the receiving hospice does not need to submit a new Notice of Election (NOE).

Revocation and Discharge Guidance
CMS expanded Sections 20.2.2 and 20.2.3 to clarify how hospice revocations and discharges affect beneficiaries. The updates respond to recommendations from the Office of Inspector General (OIG) aimed at improving transparency and consistency in hospice program administration.

The revisions prompted questions among hospice providers regarding CMS language indicating that patients who revoke hospice coverage may re-elect the benefit immediately, as long as they continue to meet eligibility criteria.

CMS clarified that beneficiaries do not have to wait until the remaining days of a benefit period expire before re-electing hospice services.

CMS Releases Four-Year Strategy for Quality and Oversight

At the same time, federal health officials have unveiled a new four-year strategic roadmap aimed at reshaping quality oversight across the U.S. health care system.

The strategy outlines several priorities for CMS, including:

• Strengthening patient safety and prevention initiatives
• Accelerating coverage decisions for innovative treatments
• Expanding the use of health data and digital oversight tools
• Reducing administrative burden for providers
• Enhancing transparency and accountability across care settings

The agency says the plan will guide regulatory development and quality initiatives affecting hospitals, nursing homes, outpatient facilities, and home-based care providers.

However, providers note that previous federal efforts to simplify reporting requirements have often produced the opposite effect—introducing new quality metrics, reporting systems, and compliance expectations.

For home health agencies and other organizations delivering care in the community, the real impact of the roadmap will depend on how CMS translates these priorities into specific regulations and program requirements in the coming years.

Bottom Line

Taken together, the proposed advance care planning measure, updated hospice policy guidance, and CMS’s new oversight strategy highlight a continuing shift toward greater documentation, quality measurement, and regulatory accountability across the health care system.

For home-based care providers, the challenge will be ensuring that new federal expectations are paired with sustainable reimbursement structures and practical implementation pathways as the regulatory landscape evolves.