Hospice Special Focus Program (HSFP) 2026 Status Update
Quick Answers: Hospice Special Focus Program
What is the Hospice Special Focus Program?
The Hospice Special Focus Program (HSFP) is a CMS enforcement program directed by the Consolidated Appropriations Act of 2021. It targets Medicare-certified hospices that CMS identifies as having "substantially failed to meet" Medicare requirements, using an algorithm finalized in CMS rulemaking.
What is the current status?
CMS paused implementation of the HSFP on February 14, 2025 to further evaluate the program. The pause remains in effect as of mid-2026; CMS has not announced a relaunch date. The first HSFP cohort identified in December 2024 was not subject to enforcement actions during the pause.
Why did CMS pause the HSFP?
Hospice industry stakeholders raised concerns about the algorithm used to identify hospices for the program, the data sources underlying the algorithm, and the potential for the program to misidentify well-performing hospices. CMS chose to pause and evaluate rather than launch a program whose execution was being questioned.
Does the HSFP pause mean less audit pressure?
No. CMS oversight has continued through other mechanisms: Targeted Probe and Educate (TPE), provisional period of enhanced oversight (PPEO), 5-day post-payment review programs, MAC-led medical reviews, and Office of Inspector General (OIG) program-integrity work. Hospice News reported in March 2026 that fraud-fight rhetoric from CMS leadership has reached a level where "no one is safe" from review.
The HSFP Timeline
- December 27, 2020. Consolidated Appropriations Act of 2021 enacted, directing creation of the program.
- FY 2024 Hospice Final Rule. CMS finalized the HSFP algorithm and operational framework.
- December 2024. CMS selected the first HSFP cohort.
- February 14, 2025. CMS paused implementation pending further evaluation.
- Through mid-2026. Pause remains in effect; no relaunch announced.
The Ongoing Oversight Landscape
Even with the HSFP paused, hospice oversight in 2026 is active and well-resourced. The mechanisms hospices should expect to encounter:
- Targeted Probe and Educate (TPE). Three-round medical review program. ADRs issued for sampled claims; feedback after each round; up to Round 3 escalation.
- Provisional Period of Enhanced Oversight (PPEO). Pre-payment medical review for newly-enrolled hospices, ensuring claims meet coverage criteria before payment is released.
- 5-Day Post-Payment Review. A faster post-payment review used by some MACs for specific patterns.
- MAC-Led Medical Reviews. ADR-based reviews initiated by the MAC's medical review unit, often triggered by data analytics that identify outlier billing patterns.
- OIG and DOJ Activity. Office of Inspector General audits and Department of Justice False Claims Act investigations continue independent of CMS enforcement programs.
What Hospices Should Still Be Doing
- Maintain audit-ready documentation. The mechanisms targeting hospices may shift, but the standard of documentation does not.
- Run internal mock audits. Quarterly self-review of a random sample of certifications, recertifications, F2F encounters, and IDG plans.
- Watch CMS oversight communications. The CMS Hospice Special Focus Program page is updated when status changes. So is the National Alliance for Care at Home and the National Hospice and Palliative Care Organization.
- Build a response capability. Even if no ADR has arrived yet, the agency should know who will own the response, where the templates live, and how chart assembly will happen.
An AI-Assisted Oversight Readiness Workflow on Hathr.AI
Hathr.AI runs on AWS GovCloud (FedRAMP High) with a BAA included on every plan. The platform is designed for the chart-review and policy-analysis work that oversight readiness requires.
- Quarterly mock-audit chart pulls. Upload a sample of recent benefit periods. Prompt: "Run this chart against the six most common ADR denial reasons. Flag any gap an auditor would identify."
- Documentation pattern analysis. Prompt: "Across these 10 recertification narratives, identify any patterns of generic language, identical phrasing, or missing required elements."
- F2F documentation review. Prompt: "Review these F2F encounter notes against the FY 2026 Final Rule requirements (signature, date, clinical findings). Flag any deficiency."
- Policy monitoring. Periodically upload the latest CMS hospice policy updates and ask Hathr.AI to summarize operational implications for the agency.
Frequently Asked Questions
Will the HSFP relaunch?
CMS has not announced a relaunch date or final form. Watch the CMS HSFP page for updates.
Was the first cohort published?
The first cohort was identified by CMS in December 2024 but was not subjected to enforcement actions due to the February 2025 pause. CMS has not publicly named the hospices in the cohort.
What does the pause mean for hospices flagged in the first cohort?
The flagged hospices are not currently subject to HSFP enforcement actions. They may still be subject to TPE, PPEO, or MAC-led reviews independent of the HSFP.
Should our agency change its compliance posture because the HSFP is paused?
No. The standard of compliance has not changed. The risk surface has shifted slightly but not contracted.
Sources and Further Reading
- CMS Hospice Special Focus Program page
- Overview of the Hospice Special Focus Program (CMS)
- National Alliance for Care at Home: HSFP resources
This article is for informational purposes only and does not constitute legal, clinical, or billing advice. Last reviewed: May 2026.
Build the audit-ready compliance posture that survives any oversight program. Start a 7-day free trial of Hathr.AI.
Our Youtube Videos
Hathr.AI is the fastest, safest way to handle sensitive medical records with HIPAA-compliant artificial intelligence. In this demo, watch how you can:✅ Summarize a patient’s medical record ✅ Generate an AI-assisted treatment plan ✅ Write a letter to the patient in plain English ✅ Suggest CPT billing codes ✅ Draft an insurance appeal for a denied claim ✅ Evaluate the case for potential malpractice — all in under 5 minutes.The only AI tool hosted in AWS GovCloud and Powered by Claude 4.0 Sonnet, Hathr.AI is trusted by hundreds of practices that need speed, security, and compliance.Learn more: hathr.ai For healthcare teams: hathr.ai/healthcare Reach out to learn more: contact@hathr.ai
#HIPAACompliantAI#ArtificialIntelligenceInMedicine#HealthcareAI#MedicalBillingAI#AIForDoctors#HIPAAAI#MedicalRecords#AIInHealthcare
Description
As Hathr.AI, we are dedicated to providing a private, secure, and HIPAA-compliant AI solution that prioritizes your data privacy while delivering cutting-edge technology for enterprises and healthcare professionals alike.
In this video, we’ll dive deep into the growing concerns around data privacy with AI tools—especially in light of recent revelations about Microsoft’s Word and Excel AI features. These new features have raised alarm over data scraping practices, where user data could be used without clear consent, leaving individuals and organizations exposed to potential privacy breaches. What makes this especially concerning is the "opt-in by default" design, which could lead to unintended data sharing.
In contrast, Hathr.AI ensures that your data stays yours. With a firm commitment to HIPAA compliance, we take the protection of sensitive healthcare data to the highest level. Our platform is built with the understanding that privacy is not an afterthought but a fundamental pillar of our design. We don’t collect, store, or sell user data, and we employ state-of-the-art encryption, secure access protocols, and clear user consent processes to keep you in full control.
We’ll also touch on why Hathr.AI, powered by advanced LLM (Large Language Models) like Claude AI, offers a secure and private alternative for businesses looking to leverage AI technology without compromising sensitive information. While some AI tools may collect or expose data through ambiguous or hard-to-find opt-out settings, Hathr.AI puts transparency and security at the forefront, offering peace of mind in an era of increasing digital vulnerability.
If you’re concerned about your privacy or looking for a HIPAA-compliant AI solution that respects your data, Hathr.AI provides the robust security, transparency, and ethical design that you need.
Key Points:
- HIPAA Compliant AI: Built for healthcare professionals, ensuring compliance with privacy regulations.
- Privacy-first: No data scraping, no data selling, full user control over information.
- Claude AI: Secure, powerful LLM tools for advanced capabilities without compromising security.
- Data Transparency: Say goodbye to hidden opt-in/opt-out toggles—Hathr.AI gives you clear, easy-to-understand privacy settings.
Tune in to learn how Hathr.AI ensures your AI tools remain private, secure, and trustworthy, while still delivering the performance and accuracy you need to thrive in a fast-evolving digital landscape.
Don't forget to like, comment, and subscribe for more insights on secure AI solutions and how to protect your organization from emerging privacy risks!
Description
Discover how Hathr AI's advanced AI tools transform federal acquisition processes with unparalleled security and efficiency. Designed for government professionals, this video showcases Hathr AI’s capabilities, including secure AI data analysis, HIPAA-compliant tools, and AWS GovCloud integration, to help streamline decision-making and document management. Perfect for agencies seeking private, compliant, and powerful AI solutions, Hathr.AI delivers tools tailored for healthcare and government needs.
Key Topics Covered:
AI-driven data analysis for governmentHIPAA-compliant, secure AI tools for federal agencies
Private deployment options with AWS GovCloud
Learn more about Hathr AI’s secure, high-performance solutions at hathr.ai and transform your agency’s acquisition process with cutting-edge AI.
Description
Discover how Hathr.AI simplifies NSF grant evaluations with advanced AI-driven compliance and proposal review tools. This video showcases Hathr.AI’s capability to streamline grant compliance checks, enhance accuracy, and save time for evaluators and applicants alike. Ideal for research institutions, government agencies, and proposal writers, Hathr.AI offers secure, HIPAA-compliant AI solutions tailored to meet the complex requirements of NSF and other grant processes.Highlights:AI-powered compliance checks for NSF grant proposalsFast, accurate, and secure evaluations with Hathr.AITailored solutions for research, government, and healthcareOptimize your grant proposal process with Hathr.AI's private, secure AI tools. Learn more at hathr.ai and transform how you handle grant evaluations and compliance.
Description
Join Hathr.AI at the Defense Information Systems Agency (DISA) Technical Exchange Meeting to explore innovative AI solutions tailored for federal and defense applications. In this session, we highlight Hathr.AI's secure, private AI tools designed for efficient data handling, HIPAA compliance, and seamless integration within government systems, including AWS GovCloud. Perfect for agencies seeking reliable AI for data analysis, document summarization, and secure decision-making, Hathr.AI provides cutting-edge technology for defense and healthcare needs.Highlights:AI tools for federal and defense data managementSecure, HIPAA-compliant AI solutions with AWS GovCloudEnhancing operational efficiency with private AI deploymentsDiscover how Hathr.AI's solutions empower government and defense agencies to stay at the forefront of innovation. Visit https://hathr.ai to learn more about our services.
Latest insights and trends
AI Healthcare Solutions: How a HIPAA Compliant LLM can Revolutionize your practice
.png)
DeepSeek AI: Interesting Methods, Dangerous Product
Challenges Finding Compliant AI: ChatGPT is Watching You
