Some hospice providers could run afoul of the Centers for Medicare and Medicaid Services if the agency reimposes its community volunteer requirement  immediately at the end of the COVID-19 public health emergency. 

During the pandemic, CMS suspended the Medicare benefit policy for hospice that requires 5% of all care hours be delivered by volunteers. Katy Barnett, director of home care and hospice operations and policy for LeadingAge, told McKnight’s Home Care Daily Pulse the PHE is likely to be extended beyond the middle of next month to Jan. 15, 2023. Still, she said CMS hasn’t been clear about when it will make providers comply with the requirement.

“If the PHE ends on Jan. 15 of next year, looking back for the past year there will be many hospices that won’t be at that 5% because they had that waiver flexibility and that’s what we’re kind of concerned about,” Barnett said. “What is the guidance going to be to surveyors to say when can you actually do the look-back of hospice volunteer hours to make sure that they meet that 5%? Will we start seeing that a year after the pandemic [ends] or will the expectation be right away to get back up to 5%?” 

Barnett said providers who are deficient in volunteers could face a monetary penalty, under a recent regulation that took effect last month. LeadingAge has been in discussions with CMS about the volunteer requirement but has not yet filed a formal request for an extended grace period until the nonprofit receives more clarity from the agency about its intentions regarding the volunteer policy. The National Hospice and Palliative and Palliative Care Organization told McKnight’s Home Care Daily Pulse it has also been in discussions with CMS about the requirement and is working to educate its members on it.

Many hospice providers lost volunteers during the pandemic, according to Barnett. She said  some older volunteers dropped out because they feared being exposed to the coronavirus in patients’ homes or in congregant settings. As a result, Barnett said providers will need to get creative in recruiting new volunteers. One LeadingAge member has already turned to a university to find new recruits.

“He has shifted the program a little to be more flexible to student hours and to have online training,” Barnett added. “He’s been really innovative in that sense.”