Hospice Special Focus Program List: Here’s What You Need to Know

The Centers for Medicare and Medicaid Services (CMS) has released its Hospice Special Focus Program (SFP) Cohort, identifying 50 poor-performing hospice agencies for increased regulatory oversight and enforcement. The SFP is designed to address deficiencies in care, ensure accountability, and protect patients from unsafe or poor-quality services.

How Hospices Are Selected

CMS uses a structured methodology, finalized in the CY 2024 HH PPS final rule, to identify poor-performing hospices for the SFP. Key factors include:

1. Survey Results:
   • Data from recertification and complaint surveys conducted over the past three years.
   • Weight is given to the number and severity of deficiency citations, especially those at the condition level that jeopardize patient safety.
2. Hospice Care Index (HCI):
   • A composite score based on Medicare claims data evaluating operational and quality metrics.
3. CAHPS® Hospice Survey:
   • Focus on caregiver-reported experience in critical areas, including:
     • Help for pain and symptoms.
     • Timeliness of receiving help.
     • Willingness to recommend the hospice.
     • Overall caregiver satisfaction with the hospice.

CMS applies this algorithm annually to all active hospices and selects 50 participants for the SFP based on these criteria. To view the 2025 list, the SFP User Guide and more, click here.

What Happens If You Are on the List?

Being selected for the SFP subjects your hospice to heightened oversight and stricter compliance requirements:

• Increased Survey Frequency:
  • A full survey at least every six months, in addition to surveys triggered by complaints or deficiencies.
  • Follow-up surveys are conducted as needed to verify corrections.
• Loss of Deemed Status:
  • Hospices accredited by an Accrediting Organization (AO) will have their deemed status suspended, placing them under CMS jurisdiction.
• Progressive Enforcement Actions:
  • Enforcement remedies, including monetary penalties and corrective action plans, may be imposed for deficiencies.
  • Persistent noncompliance could result in termination from the Medicare program.
• Public Reporting:
  • CMS will publicly share the hospice’s SFP status on its website, labeling agencies as “In Progress,” “Completed,” or “Terminated.”
• Completion or Termination:
  • To exit the program, hospices must pass two surveys within 18 months without condition-level deficiencies or unresolved complaints. Failure to meet these criteria can lead to termination from Medicare.

How to Stay Off the List

Preventive action is critical to maintaining compliance and delivering high-quality care. Steps to take include:

• Mock Surveys: Conduct regular mock surveys to identify and address deficiencies, as well as prepare your team for survey. McBee consulting services can assist.
• Staff Education: Staff training and HCAHPS education on compliance and quality standards with McBee Post-Acute Academy.
• Coding and Documentation: Ensure accuracy and compliance with McBee Hospice Coding Solutions.
• Streamline Data Submission: Use tools like SimpleConnect for Hospice to simplify and improve reporting.
• Risk Assessments: Conduct a risk assessment with the support of McBee to proactively address vulnerabilities.
• IDR Process: Utilize the Informal Dispute Resolution (IDR) process to combat deficiencies. McBee’s survey compliance team can assist with the IDR and the plan of correction.

Why It Matters

Selection for the SFP can severely impact your hospice’s reputation, financial stability, and ability to serve patients. Proactively addressing compliance and quality standards can ensure your hospice avoids the SFP cohort and delivers the best care possible.

Contact us today to learn how McBee can help your agency maintain compliance and stay off the SFP list.

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About the Author

Michelle Horner, Manager of Clinical Consulting and Education

Michelle Horner, BSN, RN, HCS-O, HCS-D, HCS-H, COS-S is the Clinical Consulting and Education Manager for McBee. With over 30 years of healthcare experience, Michelle Horner is a leading expert in home health and hospice. As Manager of Clinical Consulting & Education at McBee, she excels in Quality, Clinical, and Regulatory Consulting, designing innovative training programs that elevate care standards. A sought-after speaker at industry events, Michelle captivates audiences with her expertise and passion. She serves on the AHCC’s Board of Medical Specialty Coding and Compliance Certification HCS-D and HCS-O Committees, shaping industry standards. Renowned for driving impactful financial and clinical outcomes, Michelle is dedicated to advancing the quality of care in the home care sector.