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    October 5, 2026

    90 Days to January 1: An Addendum Readiness Plan for Hospice Admissions Teams

    By MedAuditShield Compliance Team· 9 min read

    Key Takeaways

    • From October 1 to December 31, 2026, MACs will not deny claims solely because the addendum is missing or incomplete. After that, expect full scrutiny.
    • October is for forms, packet updates, training, and building 5-day and 3-day triggers into the workflow.
    • November is for weekly election audits and confirming plan-of-care changes produce updated addendums.
    • December is for a mock ADR pull on 10 recent elections and a formal readiness sign-off.
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    Why the Next 90 Days Matter

    The election statement addendum became an every-election requirement on October 1, 2026. Every Medicare hospice patient with an election on or after that date must receive it in writing within 5 days of the election effective date, and an updated copy within 3 days when a plan-of-care change affects related or unrelated determinations.

    CMS gave hospices a short runway. From October 1 to December 31, MACs will not deny claims solely because the addendum is missing or incomplete, and they will focus on education. The requirement is still in force during that time. Only the denial consequence is paused. After December 31, expect full scrutiny.

    That makes this quarter unusually valuable. You can find and fix gaps on real admissions while the cost of a mistake is still low. The plan below divides the work into three months, each with a clear goal and a finish line.

    October: Forms, Packet, Training, and Workflow Triggers

    The goal for October is simple: every new election gets an addendum, on time, from a process that does not depend on memory.

    Adopt the CMS model format

    Start from the CMS model addendum published in August 2026. Adapting it is safer than writing your own from scratch, because reviewers will recognize the structure. Confirm your version includes unrelated conditions, items, services, and drugs, plain-language reasons, and how to dispute or appeal.

    Update the admission packet

    Remove any language that describes the addendum as available upon request. Place the addendum directly after the election statement so staff complete them together, and file them together.

    Train intake and clinical staff

    Keep training short and practical. Cover what the addendum is, why every patient now receives it, how to explain unrelated care in plain language, and how to document that coverage was discussed at election. Role-play the conversation once with a family member who disagrees with a determination.

    Build the triggers

    Put the 5-day deadline into your EHR or tracking sheet, calculated from the election effective date. Add a standing question to the IDG agenda: did anything today change what we consider related or unrelated? A yes should open a 3-day task for an updated addendum.

    November: Weekly Audits, Fixing Gaps, and Change Triggers

    The goal for November is to prove the October process works, using evidence instead of assumptions.

    Audit every new election weekly

    Review each election from the prior week against the checklist below. For small agencies this may be three or four charts. For larger agencies, review all of them if you can, or a meaningful sample from every admitting team if you cannot. The point is to catch patterns, such as one location that consistently files late.

    Fix gaps immediately

    When an audit finds a missing or late addendum, correct it, document the correction honestly, and coach the staff member the same week. Never backdate. A late addendum with a clear explanation is far better than a document whose dates do not match the record.

    Test plan-of-care change triggers

    Pick three patients with plan-of-care changes during the month. Check whether each change affected related or unrelated determinations, and if it did, whether an updated addendum was provided within 3 days and filed. This is the step most agencies discover is weakest.

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    December: Mock ADR Pull, Retrieval Test, and Sign-Off

    The goal for December is to see your records the way a reviewer will see them after January 1.

    Run a mock ADR pull on 10 elections

    Choose 10 recent elections, ideally spread across teams and locations. Ask someone outside admissions to assemble the election statement, addendum, any updated addendums, and the coverage discussion note for each, exactly as they would for a real ADR.

    Time the retrieval

    Record how long each pull takes. If anyone has to hunt across systems or ask a colleague where a file lives, you have a retrieval gap. Retrieval speed matters because ADR responses have firm deadlines, and missed deadlines produce avoidable denials such as denial code 56900.

    Sign off before January 1

    Hold a short readiness meeting with intake, clinical, the medical director, and compliance. Review audit results, mock pull findings, and open fixes. Document a sign-off decision, including any remaining risks and who owns them.

    Weekly Audit Checklist

    Use this table for every weekly election audit from October through December.

    CheckPass standardIf it fails
    Addendum presentFiled with the election statementProvide now and document why it was late
    5-day timelinessProvided within 5 days of the election effective dateCoach the admitting staff member
    Unrelated items listedConditions, items, services, and drugs named, or none statedClinical manager completes determinations
    Plain-language reasonsPatient-specific and understandableRewrite with the RN case manager
    Appeal rightsDispute and appeal steps includedReplace with the current form version
    Coverage discussionNote shows staff discussed coverage at electionAdd a training reminder
    Plan-of-care updatesUpdated addendum within 3 days when determinations changedReview IDG trigger process
    RetrievalCopy can be pulled quicklyFix filing location

    What Good Looks Like on January 1

    It helps to define the finish line in concrete terms so the sign-off meeting is a decision, not a debate. By January 1, a ready hospice can say yes to each of these statements:

  1. Every election since October 1 has an addendum filed with the election statement, and any late ones have an honest, documented explanation.
  2. Weekly audits over the last month show consistent 5-day timeliness across every admitting team and location.
  3. At least one plan-of-care change in the last month produced an updated addendum within 3 days, and the trigger came from the IDG process rather than from an audit catching it.
  4. Every patient-specific reason reviewed in December was written for that patient, not copied.
  5. The mock ADR pull assembled all 10 records without anyone hunting across systems.
  6. New staff hired in December received addendum training before their first admission.
  7. Leadership has a written list of any remaining risks, each with an owner and a date.
  8. If any statement is a no, it does not mean the agency failed. It means you know exactly what to fix in January, before a reviewer finds it for you. Write down the gap, assign it, and keep the weekly audit running until the item is closed.

    Keeping the gains after January

    Readiness tends to fade once the deadline passes. Keep a lighter version of the routine going: a monthly sample of new elections, a quarterly retrieval test, and an annual refresh of training. Add the addendum to new-hire orientation so the process survives staff turnover, which is often the real reason a working process breaks down.

    Keep the weekly summaries together in one folder. Over the quarter they become a simple record that the agency took the new requirement seriously and corrected problems as it found them.

    Roles and Accountability

    Give each part of the plan a single owner. Shared ownership is the most common reason readiness work stalls.

  9. Admissions lead: Owns the packet update, intake training, and 5-day timeliness.
  10. Clinical manager: Owns determinations, plain-language reasons, and 3-day updates after plan-of-care changes.
  11. Medical director: Supports clinical reasoning for complex determinations and joins the December sign-off.
  12. Compliance or billing lead: Owns weekly audits, the mock ADR pull, and the readiness report.
  13. Administrator: Removes obstacles, approves EHR or workflow changes, and signs the final readiness decision.
  14. A sample week for a mid-sized hospice

    To make the routine concrete, here is how one week might run for an agency admitting around fifteen patients. On Monday, the compliance lead pulls last week's elections and checks each against the audit table. On Tuesday, results go to the admissions lead and clinical manager with specific fixes. On Wednesday, the IDG meeting asks the related or unrelated question for every patient discussed. On Thursday, open fixes are confirmed closed. On Friday, a two-line summary goes to the administrator: how many elections, how many passed, and what changed. The whole cycle takes a few hours and produces a clear paper trail of good-faith effort.

    Common Implementation Mistakes to Avoid

  15. Treating October to December as optional. The requirement is already in effect. Only denials based solely on the addendum are paused.
  16. Using one reason for everyone. Copy-and-paste reasons defeat the purpose of the addendum and are easy for reviewers to spot.
  17. Forgetting the 3-day update. Most agencies build the admission step and miss the plan-of-care trigger.
  18. Leaving old packet language. Upon-request wording now contradicts your obligation.
  19. Filing in the wrong place. If the addendum is not with the election statement, it may as well be missing during an ADR.
  20. Skipping the "none" case. Patients with no unrelated items still need an addendum that says so.
  21. The addendum also connects to how CMS watches spending patterns through the new Hospice SSVI, and to the wider audit climate described in our moratorium guide. Hospices in PPEO states should also review our PPEO guide, because prepayment review raises the cost of any missing document.

    A final note on timing. HOPE replaced HIS on October 1, 2025, so many admissions teams already track HOPE windows from the election date. The addendum adds another clock that starts at the same moment. Build both into one admission timeline so staff see every election-based deadline together.

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    Frequently Asked Questions

    Start with the essentials this week: update the admission packet, begin issuing the addendum on every new election, and audit the elections since October 1. Correct missing addendums honestly without backdating, then follow the November and December steps on a compressed schedule.

    See how MedAuditShield keeps hospice ADR workflows audit-ready

    Track every ADR deadline, assign owners, and check documentation before submission.

    This article is for general information and is not legal or billing advice. Confirm requirements with your MAC and compliance counsel.

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