Hospice Compliance in 2025: 5 Challenges Every Provider Must Navigate

Hospice care is meant to offer comfort, dignity, and quality of life for terminally ill Medicare beneficiaries and their families. But while most hospice programs are deeply committed to that mission, they now face an increasingly difficult regulatory landscape shaped by fraud, new quality reporting requirements, and rising public scrutiny. 

The Centers for Medicare & Medicaid Services (CMS) has tightened oversight following cases of serious abuse. Fraudsters have enrolled ineligible patients without consent, falsified diagnoses, and billed Medicare improperly, costing the system millions. Now, even high-quality providers face more audits, more documentation demands, and higher penalties for non-compliance. 

Hospices are now required to comply with the Hospice Quality Reporting Program (HQRP) or face a 4 percent cut in Medicare payments. The HQRP includes both clinical quality data from the Hospice Item Set and feedback from the CAHPS Hospice Survey. As of FY 2024, this penalty rose from 2 percent to 4 percent for providers who do not meet reporting requirements. This data is publicly available on Medicare’s Care Compare site, giving families a new lens into hospice performance. 

Here are five of the most pressing hospice compliance challenges in 2025 and how QAPIplus helps address each one.

1. Documentation That Raises Red Flags

Hospice documentation must do more than exist. It must clearly and consistently support the care provided. Surveyors and auditors closely review records to ensure eligibility for hospice care is well documented. They look for alignment between clinical notes, interdisciplinary group (IDG) records, and the patient’s plan of care. Any mismatch can create suspicion. For example, if a visit note suggests stability or improvement while the eligibility form indicates decline, it may trigger a review of that patient’s entire record. 

The challenge grows when documentation habits vary from one staff member to another or when teams rely on outdated templates and fragmented systems. Inconsistent terminology, delayed entries, or missing assessments not only slow down internal reviews but also increase risk during surveys. Strong documentation is essential for protecting Medicare and Medicaid payments, defending against fraud accusations, and showing regulators that hospice professionals are delivering appropriate, timely, and compliant care. 

How QAPIplus Helps 

QAPIplus includes pre-built clinical audit tools specifically designed to identify high-risk areas within your organization. These tools help agencies make informed decisions about necessary updates and drive targeted process improvement projects. QAPIplus audits verify alignment between care plans and clinical notes, flag incomplete records, and support compliance with CMS and HQRP standards.   

2. Gaps in IDG and Interdisciplinary Team Notes

The interdisciplinary team is the cornerstone of hospice care. It brings together medical, social, emotional, and spiritual support for the patient and family. But if IDG meetings are not fully documented, or if participation from required team members is unclear, it creates compliance concerns. CMS requires that all disciplines contribute to the plan of care and that changes are discussed collaboratively. These expectations are not suggestions. They are conditions of participation under federal regulations. 

Many hospices struggle here because of inconsistent workflows or limited resources. Notes from IDG meetings may be entered days later, or not at all. Others rely on handwritten or emailed updates that never make it into the official record. Without complete and timely documentation, surveyors may determine that your program is not coordinating care effectively. This not only jeopardizes your regulatory standing, but also the quality of care provided to patients at the end of life. 

How QAPIplus Helps 

Many hospices struggle with IDG documentation due to inconsistent workflows and limited resources. Notes from IDG meetings are often entered days later or not at all. In some cases, handwritten or emailed updates never make it into the official record. Without complete and timely documentation, surveyors may determine that your program is not effectively coordinating care. This not only puts your regulatory compliance at risk but also compromises the quality of care provided to patients at the end of life. 

Custom Audit Tools in QAPIplus empower agencies to build targeted audits that evaluate clinician performance and overall IDG documentation practices. These tools help uncover trends, identify underperforming staff, and provide the data needed to implement meaningful, organization-wide improvements.

3. QAPI Programs That Don’t Drive Results

A meaningful Quality Assurance and Performance Improvement (QAPI) program is not just a compliance checkbox. It is a requirement that supports continuous quality improvement. CMS expects hospices to use data from the Hospice Quality Reporting Program to guide decisions, track performance, and improve care delivery. That includes analyzing hospice item set submissions, reviewing CAHPS Hospice Survey results, and using these insights to launch Performance Improvement Projects (PIPs). 

However, many QAPI programs are reactive. Reports are compiled shortly before a survey or in response to a negative outcome. This approach fails to meet the expectations of regulators and does little to improve care. Hospices must adopt systems and processes that make QAPI a daily activity. This means tracking quality measures in real time, engaging leadership in review meetings, and documenting every improvement effort with clear goals and measurable outcomes. Without this structure, organizations risk falling out of compliance and missing opportunities to elevate patient and family care. 

How QAPIplus Helps 

QAPIplus transforms QAPI from a checkbox into an engine for performance improvement. The platform supports auto-generated PI meeting agendas, AI-powered PIPs, and dashboards that track trends and benchmark against national standards. With built-in compliance alerts, your team can proactively address issues before they impact care or payment.

4. Eligibility Documentation That Doesn’t Hold Up

Medicare eligibility for hospice care requires more than a diagnosis. Providers must demonstrate that each patient has a life expectancy of six months or less and that the patient is experiencing a documented clinical decline. This must be supported by specific observations such as weight loss, decreased function, increased symptom burden, or changes in vital signs. General statements like “patient appears terminal” or “decline noted” do not meet this standard. 

The documentation must also show that the patient’s goals align with palliative care, rather than curative treatment. This distinction affects payment, compliance, and the patient’s overall experience. If records fail to make this clear, providers may be asked to repay claims, face sanctions, or come under investigation for fraud. Eligibility documentation must be thorough from the beginning of care and regularly updated throughout the patient’s time on hospice. Strong processes, clear templates, and timely clinical input are key to staying compliant and avoiding audit risk. 

How QAPIplus Helps 

QAPIplus helps hospice providers stay on top of eligibility compliance by offering documentation tracking, audit-ready templates, and centralized access to clinical data that supports Medicare’s Conditions of Payment. By enabling consistent documentation workflows and giving compliance teams visibility into gaps across branches or clinicians, QAPIplus helps reduce the risk of errors and oversights. 

The platform supports targeted reviews of records and timely interventions when eligibility documentation is missing or unclear, ensuring every patient file can withstand regulatory scrutiny and that your team can confidently defend care decisions from admission through recertification. 

Our pre-built and customizable audit tools allow clients to review, identify, and act on risks in real time. Interactive dashboards provide visibility that was previously unavailable, offering clear insights into documentation gaps and compliance risks. Agencies that fully engage with QAPIplus by entering all relevant data points gain access to robust reporting, enabling data-driven decisions and targeted process improvement.

5. Growing Scrutiny for Even the Best Providers

Hospices across the country are operating under heightened regulatory scrutiny. This is a result of ongoing efforts to eliminate fraud and abuse, particularly in areas where high numbers of new hospice licenses have raised concerns. Providers who deliver excellent care are still being audited, surveyed more frequently, and evaluated under tighter quality standards. No organization is exempt from this scrutiny. 

The pressure is amplified by the public nature of quality data. Medicare’s Care Compare tool allows patients, families, and referral sources to view scores, survey results, and performance trends. A low score or missing report can hurt your organization’s reputation, regardless of how compassionate or effective your care may be. This visibility makes it more important than ever to stay current on regulatory changes, educate staff regularly, and invest in tools that support real-time performance tracking and transparent documentation. Continuous readiness is no longer a best practice. It is a baseline expectation. 

How QAPIplus Helps 

QAPIplus supports survey preparedness with always-on compliance tracking, digital access for surveyors, and automated reports that reduce manual prep time. We help hospices stay compliant across all locations with branch-level dashboards and centralized training distribution. Whether you’re a single-site agency or a multi-branch enterprise, QAPIplus keeps you ready. 

Your Plus for Hospice Compliance 

Hospice professionals are under more pressure than ever to document accurately, report correctly, and stay ahead of changing regulations. QAPIplus is the only platform that combines clinical insight, regulatory expertise, and user-friendly technology to help hospices comply with HQRP and Medicare conditions of participation. 

QAPIplus helps you deliver better care while reducing administrative burden. Our compliance tools support every part of the process: from IDG documentation and eligibility audits to education tracking and benchmark evaluation. You get more than a software platform. You get a true partner in compliance. 

To learn how QAPIplus can support your hospice’s compliance, visit home.qapiplus.com or schedule a demo today.