A hospice billing service manages the revenue cycle that sits underneath the hospice benefit — election and Notice of Election processing, benefit period tracking, level-of-care sequencing across routine home care, continuous home care, inpatient respite care, and general inpatient care, face-to-face recertification documentation, HOPE data submission, per diem claim production, cap management, denial appeals, and A/R follow-up. Because hospice is paid per diem rather than per service, revenue is a function of days, levels of care, and documentation — not procedure volume. A specialized billing partner exists to make sure every covered day is billed at the correct level, every recertification is supported by compliant documentation, and the agency never wakes up to a cap liability it did not see coming.
AMS Solutions has run revenue cycle operations since 1992 — over 30 years. Hospice is a specialty where the compliance surface is unusually wide relative to the size of the billing operation, and where a single documentation habit repeated across a census can produce a repayment demand years later.
A Dedicated Team for Your Hospice Agency
You get a named team that learns your program: your census pattern, your IDG schedule, your GIP contracts, your attending physician relationships, and the specific documentation gaps that recur in your record. They are not rotating through a queue, and they are not learning hospice on your account.
Hospice billing failures are rarely arithmetic. They are documentation failures with a financial consequence attached, and catching them requires someone who knows what a compliant recertification narrative looks like and can tell the difference between a clinical note that satisfies the face-to-face requirement and one that merely mentions the visit. Our U.S.-Based Specialists hold AAPC credentials, and your administrator has direct phone access to the people working your claims.
Hospice Billing and Coding Expertise
The Four Levels of Care and Per Diem Sequencing
Under 42 CFR 418.302, hospice care is paid on a per diem basis across four levels: routine home care, continuous home care, inpatient respite care, and general inpatient care. Continuous home care is calculated hourly and multiplied by hours of service, with a minimum of 8 hours required in a day.
That 8-hour minimum is where most continuous home care revenue is lost. A crisis is managed across a shift, the hours are documented in the clinical note but never reconciled to the billing record, and the day is submitted as routine home care. The reverse error — billing continuous home care on a day that does not meet the hourly minimum or the crisis criteria — is an audit finding. We reconcile documented hours against billed level of care day by day, and we sequence level-of-care changes so that respite and general inpatient days align with the facility record rather than with the office’s after-the-fact reconstruction.
The Hospice Cap and Cap-Year Management
The finalized hospice cap amount for FY 2027 is $36,174.75, up from $35,361.44 in FY 2026. The cap is an aggregate limit, which means a program can look healthy every month and still be accruing a liability that is only visible when the year’s admissions and days are modeled together.
We track cap position throughout the cap year rather than reporting it retrospectively. Agencies with long-stay diagnoses, a high proportion of live discharges, or heavy referral concentration from a single facility are structurally more exposed, and those patterns are visible in the census long before they are visible in a cap calculation. The purpose of the tracking is to give ownership time to make admission and program decisions while decisions are still possible.
Face-to-Face Recertification Documentation
Under 42 CFR 418.22, a hospice physician or hospice nurse practitioner must have a face-to-face encounter with the patient prior to, but no more than 30 calendar days prior to, the 3rd benefit period recertification, and before every benefit period recertification thereafter.
Effective with the FY2026 rule, the attestation must include the signature and date of signature of the physician or nurse practitioner, and a signed and dated clinical note may satisfy the requirement rather than a separate document. That second change is operationally significant: agencies that were maintaining a parallel attestation form can, if the clinical note is properly signed and dated, stop generating duplicate paperwork. But the change only helps agencies whose notes are actually signed and dated at the time of the encounter. We audit the encounter date against the recertification date, confirm the 30-day window, and verify signature and date presence before the benefit period is billed.
HOPE Submission Timeliness
The Hospice Outcomes and Patient Evaluation (HOPE) tool took effect October 1, 2025, replacing the Hospice Item Set. Hospices must submit HOPE data within 30 days of the patient’s HOPE admission, HOPE Update Visit (HUV), and HOPE discharge dates.
HOPE introduced submission events that did not exist under HIS — the HUV in particular creates a recurring obligation mid-stay rather than only at admission and discharge. Agencies that mapped their old HIS calendar onto HOPE tend to miss HUV windows first. We track each patient’s HOPE submission events against the 30-day requirement and escalate before the window closes, because quality reporting compliance now carries a public-facing consequence: the FY2027 rule adds a Care Compare icon flagging hospices that fail to submit required quality data, effective no earlier than FY2028.
Election Statements and Notice of Election
The election statement is the legal foundation of the entire episode. If the effective date on the election statement does not match the date the agency began billing, or the attending physician designation is missing or ambiguous, every subsequent claim in that benefit period inherits the defect.
We verify the election statement before the first claim: effective date, patient or representative signature and date, attending physician designation, and consistency with the Notice of Election filed with the MAC. The NOE is then tracked through acceptance rather than transmission — an NOE that is not filed within the required timeframe creates days the agency cannot bill, and an NOE that was transmitted but rejected is functionally the same as one never sent.
Physician Services Billing
Hospice physician billing is one of the few places in the benefit where services fall outside the per diem, and the distinction between hospice-employed physician services, attending physician services, and administrative or general supervisory activities is drawn precisely. Agencies frequently bill nothing at all here because the rules feel risky, and just as frequently bill inconsistently because the physician’s role in a given encounter was never documented clearly.
We separate the encounter types in your record, confirm the physician’s relationship to the patient and to the hospice, and bill only what the documentation supports — while making sure legitimately billable physician services are not being written off by default.
Why Hospice Billing Goes Wrong
Hospice revenue problems concentrate in three places: days, levels of care, and documentation that supports eligibility.
The recurring drivers we find are: continuous home care hours documented clinically but never reconciled to the claim, or billed on days that do not meet the 8-hour minimum; general inpatient days billed without facility documentation that supports the level; face-to-face encounters performed outside the 30-day window or attested without the required signature and date; recertification narratives that restate a diagnosis rather than describing decline; election statements with date or attending physician defects that propagate across an episode; NOEs filed late or rejected without follow-up; HOPE submissions missed at the HUV; and cap exposure that accumulates unnoticed across a cap year.
The financial environment does not forgive these. For FY 2027, CMS updated the hospice payment rate by 2.3% (an estimated increase of $755 million in payments from FY 2026), finalized in CMS-1851-F on July 30, 2026, with FY2027 beginning October 1, 2026. That follows an FY2026 update of 2.6%, or approximately $750 million. Rate updates in that range do not create margin on their own — margin comes from billing the days you actually delivered, at the levels you actually delivered them, with documentation that holds up.
Our Hospice Revenue Cycle Workflow
Election and eligibility. Election statement reviewed for effective date, signatures, and attending physician designation; benefit period sequence established; Medicare eligibility and any secondary coverage verified.
Notice of Election. Filed and tracked through acceptance, with rejections worked immediately rather than at month end.
Benefit period and certification tracking. Certification and recertification dates calendared; face-to-face encounter windows monitored against the 42 CFR 418.22 requirement; attestation signature and date verified before billing.
Level-of-care reconciliation. Daily level of care matched to the clinical and facility record; continuous home care hours reconciled against the 8-hour minimum; respite and general inpatient days confirmed against contracted facility documentation.
HOPE submission monitoring. Admission, HUV, and discharge submission events tracked against the 30-day requirement.
Claim production and scrubbing. Per diem claims built with correct days and levels, run through edits, and submitted on a fixed monthly cycle.
Cap management. Cap position modeled throughout the cap year against the applicable cap amount, with exposure reported to ownership while there is still time to act.
Denials, appeals, and reporting. Every denial worked to root cause and categorized, with monthly reporting on denial reasons, days in A/R, level-of-care mix, NOE timeliness, and cap position.
Compliance and Data Security
AMS Solutions maintains HIPAA compliance across all operations, and our coding staff hold AAPC credentials. Protected health information is handled under signed business associate agreements, with role-based access controls, encrypted transmission and storage, audit logging of record access, and ongoing workforce privacy and security training.
Hospice carries heightened scrutiny around eligibility documentation and level-of-care selection, and we work accordingly. Levels of care are billed to the record — not to margin. Where a continuous home care day, a general inpatient day, or a recertification narrative is not supported by the documentation in front of us, the finding goes back to your clinical team as a query before the claim goes out.
Frequently Asked Questions
What is the hospice cap amount for FY 2027?
The finalized hospice cap amount for FY 2027 is $36,174.75, compared with $35,361.44 in FY 2026. It was finalized in CMS-1851-F on July 30, 2026, and FY2027 begins October 1, 2026. Because the cap is an aggregate annual limit, exposure should be modeled during the cap year rather than discovered at reconciliation.
How much did hospice payment rates change for FY 2027?
For FY 2027, CMS updated the hospice payment rate by 2.3%, an estimated increase of $755 million in payments from FY 2026. For comparison, the FY2026 update was 2.6%, or approximately $750 million. Both are aggregate national figures — what an individual hospice realizes depends on its wage index area, level-of-care mix, and length of stay.
When is the face-to-face encounter required, and what has to be documented?
Under 42 CFR 418.22, a hospice physician or hospice nurse practitioner must have a face-to-face encounter with the patient prior to, but no more than 30 calendar days prior to, the third benefit period recertification, and before every benefit period recertification after that. Effective with the FY2026 rule, the attestation must include the signature and date of signature of the physician or nurse practitioner. A signed and dated clinical note may satisfy the requirement rather than a separate attestation document.
How is continuous home care calculated?
Continuous home care is one of the four levels of care under 42 CFR 418.302 and is the only one not paid as a flat per diem. It is calculated hourly and multiplied by hours of service, with a minimum of 8 hours required in a day. Days that do not reach the 8-hour minimum are not billable as continuous home care, and hours documented in the clinical record but never reconciled to the claim are the single most common source of understated continuous home care revenue.
What are the HOPE submission deadlines?
The HOPE tool took effect October 1, 2025, replacing the Hospice Item Set. Hospices must submit HOPE data within 30 days of the patient’s HOPE admission, HOPE Update Visit (HUV), and HOPE discharge dates. The HUV is the event agencies most often miss, because it creates a mid-stay obligation that did not exist under HIS.
Is there a public consequence for missing quality data submission?
Yes. The FY2027 rule adds a Care Compare icon flagging hospices that fail to submit required quality data, effective no earlier than FY2028. That moves quality reporting compliance from an internal payment-adjustment issue to something referral sources and families can see directly, which is why we treat HOPE submission windows with the same urgency as claim deadlines.
Request a Hospice Billing Assessment
We will review a sample of your recent claims, level-of-care mix, face-to-face and recertification documentation, NOE timeliness, and current cap position, and give you a straight read on what we find. There is no cost or obligation for the review.
Complete the form below to get started, or call 866-973-2221 to speak directly with a hospice billing specialist.
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