✚ComplyWell
Hospice

A hospice penalty is capped at $10,000 a day, and it runs every day you are out of compliance

The bigger number is the one behind it. A condition-level finding puts the Medicare agreement itself at risk, and Medicare is the revenue. More than half of surveyed hospices are cited for the same thing — what the plan of care contains.

$10,000 a daythe cap 42 CFR 488.1245 puts on a hospice penalty, before the annual inflation adjustment
Your Medicare agreementwhat a condition-level finding puts at risk — and Medicare is the revenue
57.2%of surveyed hospices cited for what the plan of care contains

Fourteen requirements. ComplyWell watches every one of them, every morning.

The rulebook is 42 CFR Part 418, the Hospice Conditions of Participation. Fourteen of its requirements attach to an individual patient and carry a date, and every one of them was written from the citation itself. Below they are in the order surveyors cite them. ComplyWell checks each one against every patient on your census and tells the person who owes the work while there is still time to act.

1Plan of care carries all six required elementsCited at 57%
The regulation names six things every plan of care must contain: interventions for pain and symptoms, the scope and frequency of each service, the outcomes anticipated, the drugs and treatments needed, the supplies and appliances needed, and the patient or representative understanding and agreeing. ComplyWell checks each one and names the ones it cannot see. It does not judge whether the wording is clinically adequate.
42 CFR 418.56(c)
2Plan of care names every visiting discipline
ComplyWell compares who actually visited against who the plan of care lists, and names any discipline that turned up without being on it.
42 CFR 418.56(c)
3Comprehensive assessment completed within 5 daysCited at 17%
ComplyWell compares the completion date to the election date rather than assuming from the calendar, so an assessment you finished on day three never gets flagged.
42 CFR 418.54(b)
4Aide supervisory visit every 14 daysCited at 15%
If your report names supervisory visits, ComplyWell uses those. If it does not, it counts from the last nursing visit and says so plainly rather than pretending it knows.
42 CFR 418.76(h)(1)(i)
5IDG met, documented and signedCited at 12%
Cited at 12% of hospices surveyed. The interdisciplinary group has to meet, and the meeting has to leave a record that is documented and signed — a meeting that happened but was never written up counts the same as one that never happened. ComplyWell counts from the last recorded IDG and tells you when the fifteen-day window is closing.
42 CFR 418.56(b)
6Visit notes signed, and signed on timeCited at 19%
Cited at 19% of hospices surveyed for authentication alone. ComplyWell counts unsigned notes and escalates on the age of the oldest, because a note unsigned for a week is a different problem from one unsigned since yesterday.
42 CFR 418.104(b)
7Bereavement contact for up to one yearCited at 13%
A year of contact after a death, when the family is no longer on anyone's daily list and the chart is closed. The easiest requirement in the whole regulation to let quietly slip, and ComplyWell tracks it from the date it happened.
42 CFR 418.64(d)(1)
8Nursing assessment visit within 48 hours of election
The first deadline of the admission and the easiest to miss, because it lands while everyone is still arranging equipment and talking to the family. ComplyWell compares the first nursing visit to the election date.
42 CFR 418.54(a)
9Recertification before the benefit period ends
Two 90-day periods, then 60 days at a time for as long as the patient is with you. An unsigned recertification makes the whole benefit period ineligible, which is why we start counting two weeks out. ComplyWell counts from the admission date and tells you which periods are closing, with enough notice to get a signature rather than chase one.
42 CFR 418.22(a)(3)
10Comprehensive assessment updated every 15 daysCited at 11%
The update cycle that runs for as long as the patient is with you. ComplyWell reports the most recent assessment date and how old it is, and says plainly that an update it cannot see is not the same as an update that did not happen.
42 CFR 418.54(d)
11Plan of care reviewed at least every 15 daysCited at 18%
Fifteen days, every fifteen days, for every patient on service. ComplyWell counts from the most recent plan-of-care date and tells you when the window is closing.
42 CFR 418.56(d)
12HOPE update visit inside the day 6 to 15 windowFour-point payment cut
The window opens on day 6 of the election and shuts on day 15, and a missed submission carries a four-point payment cut. ComplyWell tells you the day it opens and counts down to the day it closes.
42 CFR 418.312(b)(1)
13Each ordered discipline visits within 5 days
An ordered discipline that never turns up is a plan of care the chart cannot support. ComplyWell checks each discipline on the plan against the first visit it actually made, and lists by name any that did not.
42 CFR 418.56
14Charts closed within 24 hours of the visit
Late closure is how documentation drifts away from what actually happened in the home. ComplyWell counts how many notes closed more than a day after the visit and how old the oldest one is.
42 CFR 418.104

Why hospice is the densest rulebook we run

Look at those percentages together. Plan of care content is the most cited hospice requirement in the national data, at 57% of surveyed hospices. The dated requirements around it are cited again and again: the plan of care review at 18%, the five-day comprehensive assessment at 17%, the 14-day aide supervisory visit at 15% and the IDG record at 12%. These are not exotic failures found in badly run agencies — they are the ordinary findings of ordinary surveys. See the full ranking, counted from 86,113 citations.

What they have in common is that none of them is a clinical failure. The plan of care is missing an element, not a patient. The supervisory visit happened at day sixteen instead of day fourteen. The IDG met and nobody signed the record. Every one of them is a date or a field, and a date or a field is exactly what arithmetic is good at.

Two of the fourteen carry a direct financial consequence rather than a survey one. An unsigned recertification makes the whole benefit period ineligible. A missed HOPE submission carries a four-point payment cut. Those two are worth setting a reminder for on their own.

What ComplyWell does about it

  1. You send a census export. Usually a scheduled report your EMR emails us on a recurring basis. That is a setting inside your own system — no integration, no vendor call, and nobody outside your agency gets access to your EMR.
  2. The engine counts. Every morning, every hospice rule we have your data for runs against every patient, and the brief names any rule it could not run and why. It is deterministic date arithmetic against dates from your own records — a subtraction, not a prediction. It cannot invent a deadline the regulation does not create.
  3. One brief goes to the named person. Not a dashboard nobody opens. A short email, each finding sorted into Action due or Past due, and an All clear when there is nothing open. You choose who receives it on the setup page.
  4. Every finding carries its evidence. Each one names the field and the value from your own export that produced it, and states (empty) explicitly where a field was blank. That is the trail you hand a surveyor, and no finding is raised without one.
  5. Every brief is dated. The top of the brief names the export it was built from, so you always know exactly how current the numbers are.

The two pillars in detail

Documentation Integrity

Copied-forward notes, blank required fields, disciplines visiting without an order, and signatures still missing.

Read more →

Timeline & IDG

Benefit periods, assessment windows, supervisory visits and the fifteen-day team cycle.

Read more →

Getting started

Your team sets up one recurring census export from your EMR during onboarding. After that, nobody touches it. That is a setting inside your own system — no integration, no vendor call, and nobody outside your agency gets access to your EMR. We send written instructions for your specific system, and you can also send files by hand through the client portal at any time.

Get Your Free Compliance Check

Send us one census export. We will run all fourteen Part 418 rules against your own dates and show you exactly what is open today, with the citation and the evidence behind each one — before a surveyor finds it first.

Get Your Free Compliance Check

Read the setup instructions

You get your rules, not everyone’s

ComplyWell runs the requirements for your service line and nothing else. A hospice is never asked about a monthly Kt/V, and a dialysis facility is never sent a bereavement reminder. Your rulebook is chosen by the service line on your account, and every finding names the paragraph it came from.

Fourteen clocks are running on your census right now.

Send one export. We run the hospice rulebook against ninety days of your own history and send back what is open, what is due and what has already passed — with the citation beside each one, and a plain note against anything your export did not carry the data for.

Get Your Free Compliance Check See pricing