This summer CMS made two coordinated moves on community-based palliative care, and clinicians should notice both. In the CY 2027 Home Health Prospective Payment System proposed rule, the agency clarified that skilled palliative care services may be furnished and billed under the existing Medicare home health benefit for eligible patients with serious illness – distinct from hospice, and available earlier in the disease course. Separately, in the CY 2027 Physician Fee Schedule proposed rule, CMS issued a Request for Information asking whether Medicare should develop a broader community-based palliative care benefit outside the hospice framework, and how it should be designed. As LeadingAge has noted, this is CMS explicitly seeking physician feedback. Comments on the home health rule were due August 31; comments on the fee schedule closed September 14.
Both deserve recognition. Those of us in serious-illness care have argued for years that patients need meaningful support well before a hospice conversation is appropriate. But the two actions are very different in weight. The home health provision is a clarification of existing authority, not a new benefit, and, as commentators reviewing the rule have pointed out, the home health framework is a poor fit for many of the patients palliative care exists to serve.
Home health eligibility generally requires that a patient be homebound and have a discrete skilled need, and the benefit is structured around restorative potential and measured on improvement. Serious-illness patients frequently meet none of those criteria. Many will not recover in the sense home health is built to reward; many have no isolated skilled need. What they require is continuity: additional touchpoints to manage symptoms, conduct goals-of-care conversations, deprescribe medications that no longer serve them, and coordinate with the community clinicians already involved – particularly during periods of clinical decline, when consistent presence in the home matters most. A benefit designed to discharge patients once they improve will keep excluding them.
Community-based palliative care is built precisely for that gap. It supports patients with advanced illness who remain on curative or aggressive treatment. It addresses the inadequate pain and symptom control, the absence of any conversation about what matters most, and the repeated emergency visits and admissions that too often define the final years of serious illness. Delivered well, it improves patient experience while reducing avoidable utilization.
That is why the fee schedule RFI was the more consequential of the two, and why physicians should answer it. CMS asked the right questions – the ones that will determine whether any future benefit actually reaches these patients. It asked whether eligibility should hinge on a terminal prognosis or instead on impact to daily function and caregiver strain; what the essential elements of care management should be, naming continuity with a designated team member, timely clinical support, comprehensive symptom and caregiver assessment, coordination with treating physicians, and prompt follow-up after an emergency visit or discharge; how quality should be measured; and how to guard against fraud and abuse. These are clinical questions, and they will be answered better for every physician who weighed in.
CMS also appears to be waiting for evidence before committing, and the most consequential test is now underway in New Jersey, whose Medicaid community-based palliative care benefit launched April 1, 2026. It reimburses an interdisciplinary team on a per-member-per-month basis to care for seriously ill patients alongside ongoing treatment, with no terminal prognosis required. Whether hospitals and community physicians refer their patients, whether providers see those patients often enough to manage what arises, and whether patients report a better experience will shape the case for federal action.
CMS has opened two doors and, in the fee schedule RFI, asked physicians directly what should come next. Whether this leads anywhere now depends on the clinicians who responded by the deadlines – and on demonstrating, in New Jersey and beyond, that this care delivers.
Photo: kutubQ, Getty Images
Jill Schwartz-Chevlin, MD, MBA, FACP is Chief Medical Officer at Vynca, where she leads clinical strategy for the company’s tech-enabled, home-based palliative care program, shaping scalable care models that improve outcomes for seriously ill patients while cutting avoidable utilization for health plans. She is skilled in palliative care, home-based primary care, managed care, population health, post-acute care, disease management, pay-for-performance, and healthcare innovations, with a demonstrated history of working in start-up healthcare environments caring for complex medical patients. Prior to joining Vynca, Jill led national teams and programs as Chief Medical Officer for Serious Illness as Regional Chief Medical Officer for WellBe Senior Medical, where she developed population health palliative care strategy and implementation plans, directed model optimization and standardization, oversaw clinical quality and care in five states, and achieved 4+ Star rating in all states. Previously, she was Senior Medical Officer for a private equity-backed healthcare group at full risk for over 100K patients, founded a home-based primary and palliative care practice which was profitable for more than ten years, and served as a founding Hospice Medical Director of a startup hospice that cared for approximately one thousand patients over ten years.
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