CMS’s draft 2027 home health rule proposes that Medicare cover community‑based palliative care through the existing home health benefit, a move hospice leaders say may miss the mark.
CMS outlines a new payment pathway
The agency stated that skilled palliative services could be billed under current home health benefits for patients with serious illnesses. It clarified that this coverage would be separate from hospice care and aim to support patients earlier in their disease course. Further sub‑regulatory guidance is expected, and CMS has emphasized that the policy is intended to act as a bridge between acute treatment and end‑of‑life services, positioning palliative care as a continuum rather than a terminal‑only option.
Hospice executives voice concerns
One hospice CEO told Hospice News that, while pleased CMS used the term “community‑based palliative care,” the home health framework was never intended for long‑term serious‑illness management. “Home health is not designed for longstanding serious illness management,” the executive said.
Home health requires patients to be homebound and to need skilled, intermittent care. By contrast, many palliative patients remain ambulatory, continue working, and need continuous symptom management. “Many of our community‑based palliative care patients are actively still engaged in their lifestyles,” the CEO noted.
The CEO warned that the rule’s language could confuse patients about eligibility. “People might not access care when they need care because using palliative care within the home health language is going to naturally create a gap,” he explained, adding that missed care could increase overall costs.
The proposal could raise costs.
Some hospice leaders argue for a dedicated community‑based palliative care benefit that would remove the homebound requirement and provide a clearer payment model. They acknowledge that establishing such a benefit would likely need congressional action.
James Dismond, CEO of MiraSol Health, said a longitudinal model of serious‑illness care could lower spending while improving outcomes. He suggested that a coordinated approach, rather than a fragmented benefit, would help patients stay at home, manage symptoms proactively, and avoid unnecessary emergency visits.
The rule may prompt further debate about how best to fund palliative services without restricting access for those who are not homebound.
Beyond the immediate concerns about eligibility, hospice leaders point out that the home health benefit’s structure limits the scope of interdisciplinary collaboration that is central to palliative care. The home health model traditionally focuses on nursing visits, physical therapy, and occasional physician oversight, whereas full palliative programs often involve social workers, spiritual counselors, and medication management teams working in concert over extended periods. By embedding palliative services within a framework that does not routinely accommodate such breadth, the proposed rule could inadvertently narrow the range of support that patients receive.
Another dimension of the discussion involves the timing of interventions. CMS’s statement highlights that the new pathway could reach patients earlier in the trajectory of serious illness, potentially before they become homebound. However, hospice executives stress that early engagement is most effective when it is not constrained by the episodic nature of home health visits. Continuous monitoring and rapid adjustments to treatment plans are hallmarks of high‑quality palliative care, and these practices may be hampered if providers must adhere to the intermittent scheduling mandated by home health regulations.
Stakeholders also note that the policy’s reliance on existing billing codes could create administrative complexity. Providers who are accustomed to filing separate claims for hospice and home health services would need to handle a hybrid system that blends elements of both, increasing the likelihood of coding errors and claim denials. This added bureaucracy could divert resources away from direct patient care and place additional burdens on clinicians already managing heavy caseloads.
In addition to the operational challenges, there is a strategic concern about market perception. The language of “community‑based palliative care” signals a shift toward broader accessibility, yet the association with home health may lead insurers and patients to view the service as a peripheral add‑on rather than a core component of disease management. Such misperception could affect referral patterns, with primary care physicians potentially overlooking palliative options for patients who do not meet homebound criteria.
Advocates for a standalone benefit argue that a dedicated payment stream would allow policymakers to define precise quality metrics, performance benchmarks, and reimbursement rates tailored to the unique demands of palliative care. By decoupling the service from home health, the system could more readily incorporate innovations such as tele‑palliative visits, mobile symptom‑tracking platforms, and community health worker engagement, all of which are increasingly recognized as effective tools for extending care beyond the confines of a traditional home health visit.
Finally, the broader policy conversation touches on the potential impact on Medicare’s overall financial health. Proponents of the longitudinal model suggest that early, coordinated palliative interventions can reduce downstream utilization of high‑cost settings like emergency departments and inpatient wards. By preventing avoidable hospitalizations, the system may achieve net savings that offset the upfront investment required to establish a new benefit. This perspective aligns with the agency’s stated goal of supporting patients earlier while maintaining fiscal responsibility.
