How to get ready for the hospice CoPs review

Key takeaways

• CMS has opened its first major review of the hospice Conditions of Participation in nearly two decades.
• Three public listening sessions run in October 2026: Oct 6 for administrators and associations, Oct 7 for direct care staff, Oct 14 for caregivers and families. This is the window to shape the rules.
• No rule is proposed yet. CMS is focused on eligibility, documentation, workforce, and fraud prevention.
• The best preparation is continuous: a current gap check, regular chart audits, workforce training tied to quality data, and trackable policy updates.
• Agencies that already operate this way won't rebuild when the CoPs change. They'll update a workflow.

CMS has opened its first major review of the hospice Conditions of Participation in nearly two decades, and is holding three public listening sessions in October 2026 before it proposes any rule. The Conditions of Participation (CoPs) are the federal requirements a hospice must meet to bill Medicare, and they are the standard every survey ties back to. There is no proposed rule yet, but the direction is set. The hospices that handle this well will be the ones already running quality and compliance every day, not the ones scrambling when the final language lands.

Before anything gets proposed, CMS wants to hear from the people doing the work. It is hosting three virtual listening sessions in October:

• October 6: hospice administrators and associations
• October 7: direct care staff
• October 14: caregivers, families, and patients

CMS is looking at whether the CoPs match how hospice care is delivered today, workforce challenges, barriers to contracting with hospitals and therapists, patient eligibility checks, and fraud prevention.

Why does a CoP change matter more than a typical rule update?

The CoPs are the floor. Every survey, every accreditation review, and every corrective action plan ties back to them. When they change, everything downstream changes: policies, training, documentation, audits, and what a surveyor asks to see.

Most hospices will find out what changed the hard way. A new requirement gets published. Someone updates a policy in a binder. Someone else sends a reminder email. Six months later, a surveyor asks for proof that it's actually happening, and the team scrambles.

That's how compliance works when it depends on a person holding everything together. It works fine until it doesn't.

What changes should hospices expect from the CoP review? 

More scrutiny on eligibility and documentation.

Eligibility checks and fraud prevention are on CMS's list. Program integrity is clearly behind this review. Expect documentation to be tested harder. If your team pulls charts only when an ADR arrives, you're finding problems late. An Additional Documentation Request (ADR) is a CMS request for medical records to verify a claim. If the records don't support the billing, the claim can be denied and the payment clawed back.

More weight on the workforce 

CMS is asking direct care staff to weigh in, not just administrators. Training, credentialing, and staffing are part of the conversation. Regulators increasingly want proof that staff are trained, current, and competent, not just that a policy says they should be.

Pressure to show it, not say it 

LeadingAge called the CoP review "probably overdue." Many of the current requirements were written for a much smaller, simpler hospice industry. Whatever replaces them will likely put more emphasis on evidence that programs are working. A QAPI plan that lives in a folder won't be enough.

How can a hospice prepare before a new rule is proposed?

Survey readiness is a daily operating state, not a pre-survey sprint. You don't need to guess what the final language says. You need to be able to change quickly when it arrives. That comes down to a few habits.

Know where you stand today. Run a gap check against your current CoPs. Which requirements do you meet on paper but can't easily prove? Start there. Those gaps only get more expensive once the standards tighten.

Audit continuously. If chart audits happen quarterly, or right before a survey, you have blind spots. Small, regular audits catch patterns while they're still small. Less time collecting. More time fixing.

Connect the workforce to quality. Training records, credentials, and competency checks shouldn't live in a different world from your quality data. When a chart audit shows a documentation pattern, you should be able to see who needs training and track whether it worked.

Make policy updates trackable. When a new rule lands, someone has to update policies, train staff, and confirm it happened. Do you have a way to see, in one place, who has read the new policy and who hasn't? If the answer is "we'd have to check," that's the gap to close.

Speak up. This is your chance to help shape the rules before they're written. Your day-to-day experience with what's clunky, unclear, or duplicative is exactly what CMS says it wants to hear. Send this to your team so the right people join each session.

This is doable now, and faster than most teams expect. Interim HealthCare of Albuquerque replaced manual compliance with a digital quality program in under 60 days. Agencies that already operate this way won't rebuild when the CoPs change. They'll update a workflow.

Register for the CMS listening sessions

• Administrators and associations (Oct 6)
• Direct care staff (Oct 7)
• Caregivers, families, and patients (Oct 14)

Why does continuous quality management matter for hospices right now?

 Regulatory change will keep coming. HOPE is already changing how hospices report quality. Payment rates for 2027 are being recalculated after a CMS error. Consolidation is reshaping who owns and operates hospices. Any one of these is manageable. Together, they punish organizations that manage quality in bursts. 

The hospices that handle this well won't be the ones that sprint hardest when a new rule drops. They'll be the ones with a system that keeps quality and compliance moving every day.

That's the idea behind everything we do at QAPIplus. Quality only works when information moves from capture to improvement. Capture what's happening. Analyze it. Act on it. Prove it improved. Then repeat, without waiting for a survey to force the issue. QAPIplus is clinician-built, CHAP Verified, and ACHC Product Certified.

Quality and compliance, built into daily operations. That's the best preparation for any rule change.

Frequently asked questions

When are the CMS hospice CoP listening sessions?

Three virtual sessions in October 2026: October 6 for administrators and associations, October 7 for direct care staff, and October 14 for caregivers, families, and patients.

Are the hospice Conditions of Participation changing in 2026?

Not yet. CMS has started a review and is gathering input, but no rule has been proposed. The current CoPs stay in effect until a final rule is published.

What is CMS focused on in the hospice CoP review?

Whether the CoPs match how hospice care is delivered today, workforce challenges, barriers to contracting with hospitals and therapists, patient eligibility checks, and fraud prevention.

How should a hospice prepare before the rule changes?

Run a gap check against the current CoPs, audit charts continuously instead of before surveys, connect workforce training to quality data, and keep policy updates trackable.

What is your team doing now to get ready for new hospice CoPs?

Source: CMS to Update Hospice CoPs, Hospice News