Understanding the differences in service delivery, Medicare reimbursement, and licensing requirements.
Palliative care is becoming an increasingly important service for patients living with serious or chronic illnesses. As demand grows, more hospice and home health organizations are exploring ways to provide palliative care before a patient becomes eligible for hospice or chooses to elect the Medicare hospice benefit.
But this raises several important questions for agency owners.
Can a hospice provide palliative care to patients who have not elected hospice? Can an existing home health agency provide these services instead? Does Medicare reimburse palliative care? And does an agency need additional licensing or Medicare enrollment?
The answers depend on how the services are delivered, who provides them, and which benefit or payment arrangement is used.
Understanding the Difference Between Palliative Care and Hospice
Palliative care focuses on relieving symptoms, managing pain, and improving the quality of life of individuals living with serious illnesses.
Patients receiving palliative care may continue treatments intended to cure, control, or slow their disease. They do not need a terminal diagnosis, and they are not required to be homebound.
Hospice care also focuses on comfort and symptom management, but it serves individuals approaching the end of life.
To qualify for the Medicare hospice benefit, a patient must have a certified terminal prognosis of six months or less if the illness follows its normal course and must elect the hospice benefit. Under that election, the patient waives ordinary Medicare payment for care related to the terminal illness and related conditions, except for services covered through the elected hospice and certain attending-practitioner services. Treatment intended to cure the terminal illness is generally not covered under the hospice benefit.
Hospice patients may continue receiving medically necessary treatment for unrelated conditions, subject to applicable Medicare coverage rules. Patients may also remain in hospice beyond six months when they continue to meet eligibility requirements and are appropriately recertified.
| Requirement | Palliative Care | Medicare Hospice |
|---|---|---|
| Terminal diagnosis required | No | Yes |
| Six-month prognosis required | No | Yes |
| Patient can continue curative treatment | Yes | Generally not for the terminal illness and related conditions under the hospice benefit |
| Patient must be homebound | No | No |
| Hospice election required | No | Yes |
| Dedicated Medicare benefit | No general stand-alone benefit | Yes |
| Symptom and pain management | Yes | Yes |
The simplest distinction is that hospice includes palliative care, but palliative care does not require hospice enrollment.
Can a Hospice Agency Provide Palliative Care Without Hospice Election?
Potentially, yes. However, operating a non-hospice palliative care program is different from providing services under the Medicare hospice benefit.
A Medicare-certified hospice receives reimbursement for covered hospice services after an eligible patient elects the benefit. Medicare generally pays the hospice through daily rates based on the level of care.
If the patient has not elected hospice, the agency cannot bill the Medicare hospice per diem simply because it provides supportive or palliative services.
Some hospice organizations address this by establishing a separate community-based palliative care service line.
These programs may offer physician or nurse practitioner consultations, symptom management, medication reviews, nursing support, care coordination, and patient and family education.
However, an existing hospice license does not automatically establish that the organization is authorized to furnish every non-hospice service it wants to offer. State licensing laws, professional scope-of-practice requirements, and the organization's billing structure must be reviewed.
A hospice organization may be able to operate a palliative care program under its existing corporate entity, but the appropriate state authorization and Medicare enrollment arrangements must first be established.
Can a Home Health Agency Provide Palliative Care?
Yes. In fact, home health agencies may already provide many of the skilled services that support palliative care.
A home health patient with advanced heart failure, cancer, chronic obstructive pulmonary disease, or another serious illness may require skilled nursing for symptom assessments, medication teaching, monitoring, and coordination with the treating practitioner.
The goal of these services does not always have to be recovery or improvement. Medicare may cover skilled services intended to maintain the patient's condition or prevent or slow deterioration when the applicable coverage requirements are met.
However, Medicare home health coverage generally requires the patient to be homebound and to need qualifying intermittent skilled nursing, physical therapy, or speech-language pathology services, or continuing occupational therapy after eligibility has been established. The patient must also meet applicable certification, face-to-face encounter, plan-of-care, and other coverage requirements.
For example, a patient with advanced heart failure who is homebound and needs skilled nursing to manage symptoms may qualify for Medicare home health even if the patient's condition is not expected to improve.
A different patient with the same diagnosis who can leave home without considerable effort may not meet Medicare's homebound requirement.
That second patient could still benefit from palliative care, but the services would need another appropriate payment arrangement.
The important distinction is that Medicare's homebound requirement applies to the Medicare home health benefit, not to all palliative care.
A state-licensed home health agency may be able to furnish certain non-Medicare services to patients who are not homebound, depending on state law, the agency's licensed scope, and the payment arrangement.
If the patient is admitted to a Medicare-certified home health agency for skilled home health services, the agency must also comply with applicable Conditions of Participation and assessment requirements. These obligations are not automatically eliminated because a patient is privately paying or receiving palliative-focused services. OASIS collection requirements and exemptions must be evaluated separately under current CMS guidance.
How Does Medicare Reimburse Community-Based Palliative Care?
This is where many agencies become confused.
Traditional Medicare does not have a general, stand-alone community-based palliative care benefit that pays an agency for a complete interdisciplinary program.
Instead, reimbursement may be available for individual covered services through existing Medicare benefits.
| Service | Potential reimbursement |
|---|---|
| Physician or nurse practitioner visits | Medicare Part B, when coverage and billing requirements are met |
| Skilled nursing visits | Medicare home health benefit for qualifying patients |
| Symptom and medication management | Covered professional visits or qualifying skilled nursing services |
| Care management and coordination | Certain Medicare Part B services when all code-specific requirements are met |
| Medical social services | Medicare home health when covered; other qualifying professional services may have separate payment pathways |
| Chaplain and general supportive services | Generally not separately covered as routine community palliative services under traditional Medicare |
| Comprehensive interdisciplinary palliative care | Potentially supported by health plan contracts, alternative payment arrangements, grants, or organizational funding |
For professional palliative care services, physicians and eligible nurse practitioners may bill Medicare Part B for medically necessary visits and other qualifying services.
Depending on the arrangement, the clinicians may bill individually or reassign their Medicare payments to an appropriately enrolled organization or group practice.
Organizational Medicare Part B billing may involve CMS-855B enrollment, while practitioner enrollment and reassignment are handled through CMS-855I or PECOS.
A hospice or home health agency's existing institutional Medicare certification does not automatically give it professional Part B billing privileges.
Nor does enrolling a professional group mean that Medicare will reimburse every nursing visit, social work encounter, or care coordination activity in the palliative care program.
This is why understanding the reimbursement model is essential before launching services.
Why Are Hospice Organizations Developing Palliative Care Programs?
There are both clinical and organizational reasons.
Palliative care allows organizations to support patients earlier in the course of serious illness, including patients who are not ready or eligible for hospice.
It may also improve communication between the patient, family, primary care provider, specialists, and other clinicians.
For hospice organizations, these programs can create continuity of care. A patient who receives palliative care may eventually become hospice eligible and choose to transition to hospice services.
However, that transition is not automatic, and the patient must remain free to choose their hospice provider.
From a financial perspective, some organizations also view community-based palliative care as a way to build relationships with hospitals, physicians, and healthcare systems.
But future hospice referrals are not a substitute for a legitimate reimbursement structure. Free or subsidized services must be evaluated for compliance with applicable federal and state fraud-and-abuse laws.
Many palliative care programs rely on a combination of professional billing, health plan contracts, and organizational financial support.
What Is CMS Saying About Palliative Care and Home Health?
An important development occurred in July 2026.
In its proposed Calendar Year 2027 Home Health Prospective Payment System rule, CMS specifically discussed the role of Medicare home health in delivering palliative care to patients with serious illnesses.
CMS recognized that the existing home health benefit can provide important skilled services for patients requiring symptom management, medication management, teaching, and other skilled interventions.
The agency also discussed providing additional guidance to clarify how palliative care services can be supported within existing home health coverage requirements.
This was a discussion in proposed rulemaking, not the creation of a new Medicare palliative care benefit.
Nevertheless, it highlights an important point: Home health agencies do not necessarily need a separate palliative care benefit to provide skilled nursing services that have a palliative purpose.
They must, however, satisfy the same Medicare coverage, documentation, and eligibility requirements that apply to other covered home health services.
What Should an Agency Consider Before Launching a Palliative Care Program?
Before advertising or enrolling patients in a community-based palliative care program, an organization should establish several important details.
Licensing and authorization: Does the existing home health or hospice license permit the services being proposed? Is a separate professional practice, agency authorization, or other license required?
Patient eligibility: Will the program serve Medicare home health patients, individuals who are not homebound, patients pursuing curative treatment, or a combination of populations?
Staffing and service delivery: Which services will physicians, nurse practitioners, registered nurses, social workers, and other team members provide? What documentation and supervision requirements apply?
Medicare enrollment and billing: Are the practitioners properly enrolled? Will they bill individually or through a group? What services are actually reimbursable?
Financial sustainability: How will the organization fund services that are not separately reimbursed by Medicare?
Patient transition and choice: How will the organization coordinate care if a patient becomes hospice eligible, while preserving the patient's right to choose whether and where to receive hospice care?
These questions should be answered before assuming that an existing hospice license, home health certification, or Medicare provider number is sufficient.
Plan the Program Before Expanding Services
Palliative care is not limited to hospice patients, and hospice organizations are not the only providers capable of delivering it.
Home health agencies already play an important role in providing skilled services that relieve symptoms and support patients living with serious illnesses.
Hospice organizations may also develop community-based palliative care programs for individuals who have not elected hospice, but they must establish the appropriate legal, clinical, and financial structure.
The challenge is not simply whether an organization has the staff to provide palliative care.
The challenge is determining which services the organization is authorized to provide, which patients qualify for each benefit, and how each service will be reimbursed.
Understanding these distinctions can help home health and hospice owners expand services responsibly without confusing palliative care with Medicare hospice enrollment.
Sources and Further Reading
Medicare.gov — Hospice Care Coverage
Medicare.gov — Home Health Services Coverage
CMS — CY 2027 Home Health Proposed Rule Fact Sheet
CMS — Medicare Provider Enrollment
Center to Advance Palliative Care — Billing and Coding