HIS Bundle Study | CMS Coverage Update

Summary: The Centers for Medicare & Medicaid Services modified the HIS Bundle Study policy, effective May 15, 2026. Here's what billing teams need to know about this change and how to prepare.

CMS HIS Bundle Study coverage policy changes can quietly reshape how hospice claims get coded and submitted. The Centers for Medicare & Medicaid Services is studying the Hospice Item Set (HIS) bundle structure — and that study has direct implications for hospice billing teams managing per-diem reimbursement, quality reporting, and claim submission timing. This policy does not list specific CPT or HCPCS codes in the available documentation. That alone is a red flag worth tracking closely before May 15, 2026.

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Quick-Reference Table

Field	Detail Copy
Payer	CMS
Policy	HIS Bundle Study
Policy Code	N/A
Change Type	Modified
Effective Date	May 15, 2026
Impact Level	Medium
Specialties Affected	Hospice providers, palliative care programs, HIS-reporting facilities
Key Action	Review HIS bundle submission workflows and audit your hospice claims documentation before May 15, 2026

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CMS HIS Bundle Study Coverage Criteria and Medical Necessity Requirements 2026

The HIS — Hospice Item Set — is CMS's standardized data collection tool for hospice quality reporting. CMS uses HIS data to assess care quality and to link that data to Medicare hospice reimbursement under the Hospice Quality Reporting Program (HQRP).

The "HIS Bundle Study" refers to CMS's structured examination of how HIS measures are grouped — or bundled — for reporting and payment purposes. The underlying question is whether the current bundle structure accurately reflects medical necessity and care delivery patterns across hospice populations.

This matters for your billing team because any changes to how CMS defines or weights the HIS bundle can affect whether your claims pass automated review, how your hospice is scored on quality metrics, and ultimately whether your per-diem rates face adjustment.

CMS has not published specific CPT or HCPCS codes in connection with this policy modification in the available documentation. If you're asking whether this coverage policy includes a code-level coverage determination, the answer right now is no — but that doesn't mean your billing operations are unaffected.

What the HIS Bundle Covers

The HIS collects data across two required forms: the HIS-Admission and HIS-Discharge. Hospices must submit both for every Medicare or Medicaid patient they serve. The bundle study is examining whether those two reporting events — and the measures embedded in them — should be restructured, expanded, or reweighted.

Under the current coverage policy, hospice reimbursement flows through four levels of care: Routine Home Care (RHC), Continuous Home Care (CHC), General Inpatient Care (GIN), and Inpatient Respite Care (IRC). The HIS bundle study could influence how CMS evaluates medical necessity documentation tied to each of those levels.

Prior authorization is not currently required for standard Medicare hospice enrollment. However, CMS has increased scrutiny of hospice elections and level-of-care determinations in recent years. If this study results in new documentation thresholds tied to HIS measures, prior authorization requirements or pre-claim review processes could follow in a subsequent rulemaking.

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CMS HIS Bundle Study Exclusions and Non-Covered Indications

The available policy documentation does not specify formal exclusions or non-covered indications tied to this modification. CMS has not designated the HIS Bundle Study as applying to any experimental or investigational procedures.

That said, hospice providers should watch for one common downstream risk: if your HIS submissions are incomplete or untimely, CMS can apply a 2-percentage-point reduction to your market basket update. That's not a claim denial in the traditional sense, but it functions like one at the aggregate revenue level.

Incomplete HIS data has historically triggered payment reductions and compliance reviews. If this study leads to new bundle definitions, hospices that don't update their HIS submission workflows before the effective date risk being caught mid-cycle with outdated processes.

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Coverage Indications at a Glance

Because the available policy documentation does not include specific diagnosis codes or indication-level coverage criteria, the table below reflects the known HIS reporting structure and its connection to Medicare hospice coverage status.

Note: This table reflects known HQRP reporting rules and should be updated once CMS publishes the full HIS Bundle Study findings and any resulting policy revisions.

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CMS HIS Bundle Billing Guidelines and Action Items 2026

The lack of specific code-level data in this policy modification is itself actionable information. Here's what your billing team should do before May 15, 2026.

Copy Action Items

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CPT, HCPCS, and ICD-10 Codes for the HIS Bundle Study Under CMS Policy N/A

The available policy documentation for the CMS HIS Bundle Study does not list specific CPT, HCPCS Level II, or ICD-10-CM codes.

This is not unusual for CMS policy modifications tied to quality reporting studies. The HIS bundle is a reporting infrastructure change, not a procedure-level coverage determination. It doesn't map directly to a CPT code the way a surgical procedure or durable medical equipment item does.

Hospice Billing Codes Commonly Associated with HIS Reporting

While these codes are not specified in the policy documentation itself, your HIS bundle compliance is directly tied to claims submitted under the following revenue codes and conditions codes. Include these in your internal audit scope.

These codes represent standard hospice claim submission elements. They are not derived from the HIS Bundle Study policy documentation. Verify against your current MAC's billing guidelines before updating your charge capture.

Your Medicare Administrative Contractor (MAC) is the right starting point if you need guidance on how the HIS Bundle Study affects your specific claim submission requirements. Palmetto GBA, CGS, and NGS each publish hospice-specific billing guidelines that should be cross-referenced with any CMS policy modification of this type.

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The Real Issue with This Policy Change

Here's the honest take: a policy labeled "HIS Bundle Study" with no published codes and a single-sentence description is a gap in CMS's public communication — not a gap in the underlying policy substance.

CMS is actively reshaping hospice quality reporting through the HQRP, and the HIS bundle is central to that effort. Billing teams that wait for CMS to publish fully annotated, code-level guidance before acting tend to be the ones scrambling after a final rule drops in August.

The effective date of May 15, 2026 gives you a clear window. Use it to shore up your HIS submission workflows, audit your level-of-care documentation, and get your EMR vendor on record about their update timeline. That's not overcaution — that's how hospice billing teams avoid the revenue hits that come from being reactive.

If you're unsure how this modification applies to your specific hospice program or your MAC's local coverage determination framework, talk to your compliance officer and your hospice billing consultant before May 15, 2026.

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