Hospice 2026: Face-to-Face Rule — Cura Compliance Consulting

Hospice in 2026: The New Face-to-Face Attestation Rule, Explained

The Medicare hospice rules for the 2026 fiscal year are now in force, and one change in particular matters for day-to-day documentation. The FY 2026 Hospice Final Rule (CMS-1835-F) was issued on 1 August 2025 and took effect on 1 October 2025. Here is what changed, in plain language.

The payment update

For FY 2026, CMS increased hospice payment rates by 2.6% (a 3.3% market basket increase, reduced by a 0.7% productivity adjustment). The aggregate hospice cap rose by the same 2.6%. Useful to know for budgeting — but the operational changes below are what you actually have to act on.

The face-to-face attestation change

To recertify a patient for hospice care beyond a certain point, a physician or nurse practitioner must conduct a face-to-face encounter and attest to it. The 2026 rule clarifies two things:

  1. The attestation must be signed and dated by the physician or nurse practitioner who performed the encounter.
  2. A signed, dated clinical note can satisfy the attestation requirement. In other words, if your face-to-face encounter note is clearly identified as the face-to-face encounter and carries the practitioner's signature and date, that can do the job — you do not necessarily need a separate standalone attestation document.

This sounds small, but it removes a common source of technical denials. Many hospices were tripped up by missing signatures, missing dates, or confusion over whether the clinical note "counted." The rule now makes the expectation explicit. The practical lesson: build a template that captures the signature and date every time, and train your clinicians to use it without exception.

Who can admit a patient

The rule also confirms that any physician member of the interdisciplinary group (IDG) — not only the medical director — may recommend admission to hospice care or confirm that the admission criteria are met. This aligns the admission rules with the certification rules and gives hospices a little more practical flexibility in how they staff the admission process.

The HOPE assessment

Alongside these changes, CMS has moved the hospice quality program onto the new HOPE tool (Hospice Outcomes and Patient Evaluation), which replaces the older assessment instrument. Implementation began on 1 October 2025. Under the Hospice Quality Reporting Program, a high proportion of required HOPE assessments must be submitted within the set timeframe, or your agency risks a payment penalty. If your team's HOPE training is not already well underway, that is the most urgent item on this list.

What hospice owners should do now

  • Update your face-to-face template so it always captures the practitioner's signature and date, and is clearly labelled as the face-to-face encounter.
  • Confirm your HOPE workflow — who completes assessments, how they are submitted, and how you track the submission deadlines.
  • Review your admission policy to reflect that any IDG physician may recommend admission.
  • Refresh your policies and procedures generally. Hospice rules change every year, and a documentation policy written to older rules is a quiet compliance risk.

Keeping all of this current is unglamorous but essential — and it is exactly the kind of work that should not cost a fortune. We build and update hospice compliance documentation at a fixed, published price, delivered entirely online, so you always know what you are paying and your program always reflects the current rules.


Need your hospice documentation brought in line with the 2026 rules? See our fixed-price compliance services, or book a paid Discovery Call and we will tell you exactly what needs updating — honestly, even if that means pointing you elsewhere.

This article is general information, not legal advice. Federal rules change; we confirm the current detail as part of every project.

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