Palliative care is specialized medical care focused on improving quality of life for patients with serious illness by managing symptoms, pain, and stress, regardless of diagnosis or stage of disease. Care can take place in different settings, including inside and outside of the home. This article will cover how palliative care fits in to the post-acute care continuum and how an agency can decide whether adding this service will be a good fit.
Managing the complexity of palliative coding can prove challenging. Lack of documentation, minor mistakes, and improper coding can tie up reimbursement. This can produce financial challenges and get in the way of providing exceptional patient care. Learn how experts at HealthRev Partners can help!
What is the primary focus of palliative care?
The focus of palliative care is the full care of the patient. It includes establishing goals and discussing goals of care from an interdisciplinary angle. Focuses of palliative organizations can range from pain and symptom management, making sure patients are comfortable, and advocating for the goals of care that have been created for the patient, making sure that they’re honored and protected.
Is there regulation of palliative care?
There are not a lot of regulatory boundaries around palliative care. There is a lot of advocacy in the industry to define palliative care. Due to the infancy of the state of regulation, not all palliative programs are created equal.
Where does palliative care take place?
Palliative care has been delivered in hospitals for many years but there has been a recent emergence of community based palliative care where providers are seeing patients in their homes. Palliative care is also on the rise in nursing homes and assisted living facilities.
Who benefits from receiving palliative care?
Palliative care offers advocacy for navigating goals of care and protecting those goals. It also allows pain and symptoms to be managed at an acceptable level while still on a curative trajectory. It is most beneficial for those patients who find themselves with a serious illness or may have found themselves with complex care needs- like multiple specialists and providers.
Who pays for palliative care?
Palliative care is typically billed under Medicare Part B as a fee-for-service model, with services provided by physicians, nurse practitioners, and other qualified providers.
In recent years, coverage options have expanded beyond traditional Medicare. Many Medicare Advantage plans and commercial payers now include palliative care benefits, often as part of broader care management or serious illness programs.
Reimbursement levels and structures continue to shift with annual updates to the Medicare Physician Fee Schedule, which can impact how palliative care services are delivered and scaled.
For home health and hospice organizations, understanding payer mix and reimbursement variability is critical when evaluating or expanding a palliative care service line.
What about commercial payers? What about Medicare Advantage plans?
Options for payment are continuing to evolve and the commercial and Medicare Advantage plans are changing. There are markets where palliative care is simply a private pay situation. Commercial insurances may cover palliative care or possibly a fee for service, which is more likely with a Medicare Advantage program. Risk based management programs may have payer arrangements that would cover a patient.
If it’s a traditional fee for service, the patient may have copays or deductibles that would traditionally work with any other specialist or provider.
How does palliative care fit in to the post-acute care spectrum?
Palliative care finds itself on the spectrum of home health and hospice because it can be offered with aggressive treatment without the participation requirements. Some states allow it to be given concurrently with home health. Should a patient find themselves not progressing in home health but they are seriously ill and are also not ready for hospice yet either, palliative care can provide a really good level of care.
Palliative Care vs. Hospice: What’s the Difference?
The main regulatory difference is that there are no conditions of participation yet set for palliative care like there are for hospice. Palliative care can be given concurrently with aggressive treatment. Palliative care protects the patient’s wishes and goals of care but is upstream from hospice care, so it’s giving that interdisciplinary care without the conditions of participation of hospice care.
Hospice care requires that a patient has a life expectancy of six months or less and the focus is to allow the patient to focus on their goals for comfort and support. Hospice care requires a written certification from their attending stating the patient has a life expectancy of six months or less.
Palliative providers aren’t often needed when hospice takes over because they’re giving care in similar ways. When Hospice begins Palliative Care should end. To have both concurrently is a big red flag for payers. Also, Medicare will not cover home health and hospice at the same time. A Medicare patient gets two 90 day benefit periods then unlimited 60 day benefit.
How the HOPE Tool Is Changing Hospice Care
In 2025, CMS began implementing the Hospice Outcomes and Patient Evaluation (HOPE) tool, replacing the Hospice Item Set (HIS). This new framework collects patient-level data at multiple points throughout a hospice stay, rather than only at admission and discharge.
For organizations operating in both hospice and palliative care, this shift reflects a broader industry move toward continuous quality measurement and outcomes-based care.
As regulatory expectations evolve, agencies considering a palliative care service line should be prepared to align with more robust data collection, quality reporting, and care coordination standards across the continuum.
Is palliative care a service line your agency can offer?
Palliative care can bridge the continuum of care that an agency can offer between home health and hospice. There are items to be considered and this list is not exhaustive:
- Current patient census. If an analysis of a current patient census shows patients who are in between the home health and hospice transition or that the agency is possibly even losing patients as they transition through the spectrum of care, a palliative care program may be a logical addition. It may even be possible to run a palliative care program within a home health program. Those specifics can be explored within your state licensure.
- Outcomes. If the agency has strong outcomes and strong relationships with community partners, it could be worth looking to see what value can be added by including a palliative program within your market.
- Staffing. Take inventory of staffing and who is providing care within the organization. Consider the nurses or CNAs and other disciplines of care that will be required to run a palliative program that offers the full spectrum of care for patients to meet the goals and philosophies of the agency.
All in all, the program has to fit from a healthcare, community, and business model for it to be a viable, profitable addition to the services an agency offers.
