Post-PHE Hospice Regulation: Preparing for the Reinstated Volunteer Requirement

The return of volunteer requirements is among the regulatory changes being implemented with the end of the COVID-19 public health emergency.

The U.S. Centers for Medicaid & Medicaid Services (CMS) in 2020 issued a number of flexibilities intended to ease burdens on health care providers during the pandemic. This included the temporary lifting of the requirement that volunteers provide at least 5% of hospice patient care hours. CMS will reinstate the rule as of Jan. 1, 2024.

Quickly resuming compliance with the volunteer standard is among the most significant regulatory developments for hospices to navigate in a post-pandemic environment, according to Judi Lund Person, vice president of regulatory and compliance, National Hospice and Palliative Care Organization (NHPCO).

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“The volunteer requirement has been an important piece of what [hospices] are looking at post-PHE,” Lund Person told Hospice News. “It’s a reporting requirement that the CMS surveyor attention could continue on. Hospices may get a standard level survey citation if they don’t meet that 5% requirement. So it is a very, very important regulatory bucket.”


This is the final piece of a four-part series by Hospice News that examines what hospices need to know about the changing regulatory conditions.


CMS had waived the volunteer requirement due to the need to social distance in a time of reduced service capacity, the agency indicated.

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Surveyor determinations of hospice provider’s compliance with the volunteer requirement also will resume on Jan. 1, 2024, CMS noted in recent guidelines.

“That gives hospices a chance to get their volunteer program running and get to that 5% place before they have to start reporting on it again,” Lund Person said. “That’s 5% of both contracted and employed staff hours that has to be done by volunteers. What does that look like now?”

Another piece of the recruitment puzzle

Many hospices saw volunteerism plunge drastically as they suspended activities during the pandemic. Some are still working to rebuild their ranks, applying various volunteer recruitment and retention strategies alongside their other workforce initiatives.

Roughly 78% of hospice and palliative care providers around the globe indicated “less or much less” use of volunteers since the pandemic’s onset, according to a 2022 study in the International Journal of Health Policy and Management.

The volunteer requirement is one more puzzle piece that hospices have to factor into their recruitment strategies in today’s “new normal,” according to Mollie Gurian, vice president of home based and HCBS policy at LeadingAge. 

The hospice workforce has seen varied shifts throughout the pandemic, including higher volumes of contracted clinicians amid staff quarantine periods, and increased rates of burnout and turnover.

Rebuilding their pool of volunteers is among the toughest feats facing hospices, and a longstanding problem that had been worsened by the COVID, Gurian said.

“There was this problem with getting to the volunteer threshold that was coming before the pandemic,” Gurian told Hospice News during a recent Hospice News webinar. “I think that process was exacerbated by COVID, as with many of our workforce challenges. The volunteer issue is one that was just sped up by COVID. Hospices are going to have to adapt more quickly in trying to get different kinds of people engaged with volunteering.”

The volunteer issue is one that was just sped up by COVID. Hospices are going to have to adapt more quickly in trying to get different kinds of people engaged with volunteering.

—Mollie Gurian, vice president of home based and HCBS policy at LeadingAge

Recruiting a broader demographic

Retired seniors are the most common population to engage in hospice volunteering, and with more of these individuals reaching a need for hospice care themselves in coming years, providers are facing staff and volunteer supply and demand challenges that mirror each other, Gurian explained.

“Hospices have been struggling for many years now about how to engage different generations in volunteering for hospice and adapting hospice volunteering to different generational needs of people who are still working, who are younger people or teenagers,” she said.

Some have collaborated with local high schools, colleges and universities to develop programs that both educate younger generations about end-of-life care and provide volunteer opportunities.

Hospices have also sought partnerships to develop community service projects for volunteers that fall both inside and outside of direct patient care hours, including landscape work at inpatient facilities and food preparation assistance for their home-based patient meal delivery services.

Configuring the 5% hospice volunteer requirement back into the patient care equation will take a creative and multigenerational approach, according to Dr. Cameron Muir, chief medical officer at the National Partnership for Healthcare and Hospice Innovation (NPHI).

“It just begins with a kind of innovative approach to thinking about a new generation of volunteers engaged for different reasons,” Muir said during the webinar. “That will then allow for perhaps a build out of a new volunteer core that could also impact direct patient hours. This an opportune, great area for innovation and creative thinking.”

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