The Biggest Operational Change: Why Every Hospice Needs to Rethink the Election Statement Addendum
The long-anticipated FY 2027 Hospice Final Rule has finally been released, and hospice leaders across the country are asking the same questions:
- What changed?
- What does it mean for my organization?
- What do we need to do before October 1?
Over the next several weeks, we’ll break down the most important operational and compliance changes in the FY 2027 Hospice Final Rule. We begin with what we believe is the most significant change of all—the mandatory Hospice Election Statement Addendum.
Our goal is to make that process a little easier.
This article isn’t intended to replace the Final Rule (all 59 pages of it!), nor does it cover every payment provision, technical revision, or regulatory nuance. Instead, we’ve pulled out the operational changes we believe will matter most to hospice leaders and managers.
While we strongly encourage every organization to review the Final Rule in its entirety, we hope this summary serves as a practical roadmap to help you focus on the changes that deserve your immediate attention over the next several weeks.
Every hospice is unique, and the way these requirements apply may vary depending on your policies, workflows, EMR, and current compliance practices. If you’re unsure how these changes affect your organization—or simply want help translating the regulations into practical, compliant operations—our consultants are always happy to help.
The Mandatory Hospice Election Statement Addendum
In our opinion, this is the single most significant operational change affecting day-to-day hospice operations in the FY 2027 Final Rule.
CMS has transformed the Hospice Election Statement Addendum from a document that was only required upon request into a standard part of every Medicare hospice admission.
This change places the responsibility squarely on the hospice to proactively explain coverage decisions rather than waiting for a patient or family member to ask. The goal is greater transparency, ensuring patients, families, and other healthcare providers clearly understand what hospice will—and will not—cover under the Medicare Hospice Benefit.
If you’re one of our Hospice Support Specialists clients, this change probably doesn’t come as a surprise.
We’ve been encouraging organizations to prepare for this shift for years because we believed it was the logical next step in CMS’s ongoing focus on transparency, relatedness determinations, and beneficiary education. Thankfully, many of our clients already have much of the necessary workflow in place.
Maybe we’re not alarmists after all—we’re just pretty good at reading the tea leaves.
This Final Rule reinforces something we’ve been telling clients for years:
Medicare’s expectations rarely appear overnight. They evolve gradually, and organizations that pay attention to those signals are almost always better prepared when regulatory changes become mandatory.
So, What Actually Changed?
Although many of the underlying requirements are not new, the operational impact is significant because these requirements now apply to every Medicare hospice election—not just when the Addendum is requested.
In other words:
The rules haven’t changed nearly as much as the frequency with which you’ll need to follow them.
1. The Addendum Is No Longer Optional
Prior to October 1, 2026, hospices were only required to prepare and furnish the Addendum when it was requested by:
- The patient
- The patient’s representative
- A non-hospice provider
- A Medicare contractor
Beginning October 1, hospices will now be required to provide the Medicare Patient Notification of Hospice Non-Covered Items, Services, and Drugs (commonly called the Hospice Election Statement Addendum) to every Medicare beneficiary who elects hospice care.
This is no longer an optional document prepared only upon request—it is now a required and routine part of every Medicare hospice admission.
2. The Five-Day Rule Now Applies Every Time
The five-day timeframe hasn’t changed.
What has changed is how it applies.
Instead of starting only after a request is made, every Medicare hospice admission now starts the five-day clock for furnishing the Addendum.
Organizations will need reliable workflows and tracking systems to ensure every admission meets this requirement.
3. Updating the Addendum Is Now Part of Routine Care
Hospices have always been required to update the Addendum within three days whenever changes to the plan of care affect coverage determinations.
The difference is that every patient will now have an Addendum, meaning every applicable change in coverage determinations must now be reflected through an updated Addendum within three days.
4. Your Communication Process Doesn’t Change—Its Frequency Does
This isn’t really a new requirement.
Hospices have always been expected to communicate with non-hospice providers regarding relatedness and coverage determinations.
CMS specifically notes that hospices already have communication systems in place under the Conditions of Participation.
The difference is that the Addendum will now routinely be available as a standardized communication tool instead of existing only when someone requested it.
Because every hospice election will now include an Addendum, hospices should ensure there is a process for making the Addendum available to non-hospice providers and Medicare contractors when needed to:
- Coordinate care
- Support relatedness determinations
- Facilitate accurate claims processing
Key Takeaway
The real change isn’t the rule itself—it’s that an exception process has become a standard operating procedure.
This isn’t just an admission form—it touches almost every part of your admission process.
Hospice leaders should immediately evaluate the following areas and implement changes where needed:
- Admission packets
- Tracking systems for required documents
- Audit process for admission paperwork
- EMR workflows
- Staff education
- Admission scripts for all teammates who complete information visits and consents (especially admission nurses and case managers)
- Coverage determination process
- Relatedness determination and Addendum review process
For many hospices, this will require a significant workflow redesign.
One additional question every organization should answer is:
Who Owns This Process?
Someone within the organization must own this process.
That person should be responsible—and accountable—for ensuring the Addendum is:
- Completed accurately
- Signed
- Updated when necessary
- Tracked through completion
Like many regulatory requirements, compliance depends less on the form itself and more on having a reliable, well-managed process behind it—and someone who owns it.
Don’t Overlook the Signature Requirement
While the signature requirement itself has not changed, the increased emphasis on the Addendum makes this a perfect time to review your organization’s compliance process.
The Addendum must be signed by the patient or the patient’s representative.
If the patient or representative refuses to sign, the hospice must document the reason for the refusal in accordance with Medicare requirements.
Too often, hospices focus on providing the Addendum but fail to verify that a signed copy is returned to the medical record.
This is far more than a documentation issue—it is an election issue.
During ADRs, TPEs, UPICs, and other Medicare reviews, we routinely see hospices unable to produce a properly executed Addendum because there was no process to track signatures or follow up on missing documents.
An unsigned Addendum—or one without documentation explaining why the patient or representative refused to sign—can call the validity of the hospice election into question and create completely avoidable claim denials.
Final Takeaway
CMS wants hospices to proactively explain coverage decisions—not reactively explain them after a patient, family member, or auditor asks the question.
Organizations that treat the Addendum as “just another admission form” are missing its purpose.
Going forward, it should become an integral part of:
- Your admission discussion
- Your relatedness determination process
- Ongoing communication with patients
- Family education
- Communication with community providers
The Addendum is only a form. Compliance comes from the process behind it.
Monday Morning Action Plan
☐ Identify who owns the Addendum process.
☐ Review your current admission packet.
☐ Audit ten recent admissions for current compliance.
☐ Review your EMR workflow.
☐ Update admission scripts.
☐ Build a tracking report.
☐ Educate all staff involved in admissions.
☐ Review your relatedness determination process.
☐ Identify additional education needs and develop an implementation timeline.
Need Help Preparing for October 1?
The FY 2027 Final Rule requires more than policy updates—it requires operational changes.
Hospice Support Specialists helps organizations translate Medicare regulations into practical workflows, education, policies, audits, and compliance processes that work in the real world.
Whether you need:
- Policy review
- Workflow redesign
- Staff education
- A complete implementation strategy
our team can help your organization prepare with confidence before October 1.
The Bottom Line
The hospices that navigate these changes successfully won’t necessarily have the best forms—they’ll have the best systems for ensuring those forms are completed accurately, consistently, and every single time.
