LeadingAge Comments on FY 2027 SNF PPS Rule
LeadingAge submitted comments on June 1 on the Fiscal Year 2027 Skilled Nursing Facilities (SNF) Prospective Payment System (PPS) proposed rule. In comments, LeadingAge supports updates to the SNF Quality Reporting Program including removal of two COVID-19 vaccination measures from the program, the revision of data submission timelines, and expansion of the data pool to include all SNF patients regardless of payer source. Acknowledging the potential for administrative burden added by this proposal, LeadingAge encouraged CMS to work with other payers to adopt a single assessment, such as the MDS, to be used for all billing and coverage determinations across payers. LeadingAge also provided feedback to CMS on considerations for future development of a SNF-specific wage index and responded to a request for information on the patient-driven payment model. In response to this request, LeadingAge advocated against any future implementation of adjustment factors to address what CMS has coined “case-mix creep”, pointing out that what CMS is observing is more likely improved accuracy in assessment and coding of patient conditions and providers should not be paid less for providing care simply to establish budget neutrality. Read LeadingAge’s comments here.
LeadingAge Submits Comments on FY2027 Hospice Wage Index Proposed Rule
On June 1, LeadingAge submitted our comments on the Fiscal Year 2027 Hospice Wage Index Proposed Rule. Our press release on the rule comments is available here. The 30-page letter goes into detail on our concerns regarding the nonhospice spending sections of the rule. LeadingAge understands CMS’s concerns with the continuing increases to nonhospice spending. However, as we share in our executive summary, “we are gravely concerned that the proposals in this rule will not address the root problems of nonhospice spending and instead will add additional burden to hospices and have a chilling impact on access to services.”
This direction was based on the tremendous amount of feedback we received from our members who were concerned with being held accountable for other providers billing Medicare when they know a patient is on hospice. To that end, LeadingAge offered an alternative proposal to CMS’s proposal for a universal election statement addendum for every hospice enrollment. Instead, LeadingAge recommended CMS eliminate the existing modifier loophole in the billing for services outside of the hospice benefit. This would require changes to the Common Working File to reject any claim without the GV or GW modifier and requirements that providers billing GW or GV must include a copy of the addendum from the hospice, which they can obtain right now according to CMS subregulatory guidance without requiring an addendum to be signed by every single patient. In addition to comments on nonhospice spending, we included extensive comments on the wage index and community based palliative care RFIs based on member feedback.
OIG Reports Says MA Organizations Overpaid $462M
The Health and Human Services Office of the Inspector General (HHS OIG) issued a report in May 2026 where it reviewed a sampling of 97 enrollees’ diagnoses code submissions from Medicare Advantage Organizations (MAOs) and found that in all cases the MAOs submissions related to high-risk acute stroke diagnosis codes were unsupported. In this case, a physician data record included the diagnosis but there was no corresponding inpatient or outpatient hospital data with this diagnosis in the same year. Based upon these findings, HHS OIG estimates that CMS made $462 million in potential net overpayments to these MAOs in 2021 and recommends a procedural change to prevent these overpayments in the future. The full report can be read here. This report gives more fuel to the concerns raised by MedPAC and members of Congress about some MAOs upcoding practices, which lead to a higher risk score for a beneficiary and in turn result in higher payments to MAOs.
LeadingAge Report Portal Now Updated with Hospice Data
The LeadingAge Report Portal has been updated according to the latest data from the Centers for Medicare & Medicaid Services (CMS) on hospice providers. Hospice members can access their Trend Reports based on the Care Compare quarterly refresh that includes updates to HIS quality measures, Hospice CAHPS measures and the bi-yearly Star Rating refresh. Of note, this is the first quarter of data since the Hospice CAHPS survey changers took effect, and the national response rate increased by 1%. We are hopeful to see additional response growth in future quarters. LeadingAge members can access their updated reports on the Report Portal using their LeadingAge login.
