The return of volunteering requirements is one of the regulatory changes being implemented with the end of the health emergency from COVID-19.


The US Centers for Medicaid and Medicaid Services (CMS) in 2020 issued a set of flexibilities intended to ease the burden on health care workers during the pandemic. This included temporarily lifting the requirement that volunteers provide at least 5% of patient care hours in hospice. CMS will roll back the rule effective January 1, 2024.

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


The volunteering requirement was a big piece of thing [hospices] they’re looking at post-PHE, the Lund Person told Hospice News. It is a reporting requirement that the CMS surveyor’s focus could continue on. Hospices can get a standard-level survey citation if they don’t meet the 5 percent requirement. So it’s a very, very important regulatory bucket.

This is the latest piece in a four-part Hospice News series examining what hospices need to know about changing regulatory conditions.

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

Surveyor determinations on hospice providers’ compliance with the volunteer requirement will also resume on Jan. 1, 2024, CMS noted in recent guidance.

This gives hospices a chance to kick-start their volunteer program and hit that 5 percent before having to start reporting on it again, Lund Person said. This is the 5% of contracted and employed staff hours that must be done by volunteers. What does he look like now?

Another piece of the recruiting puzzle

Many hospices have seen volunteer work plummet as they put their activities on hold during the pandemic. Some are still working to rebuild their ranks, applying various volunteer recruitment and retention strategies in conjunction with their other workforce initiatives.


According to a 2022 study in the International Journal of Health Policy and Management, approximately 78% of hospice and palliative care providers worldwide have reported little or much less use of volunteers since the start of the pandemic.

The volunteer requirement is another piece of the puzzle hospices need to factor into their recruiting strategies in today’s new normal, according to Mollie Gurian, vice president of home policy and HCBS at LeadingAge.

The hospice workforce has seen various shifts during the pandemic, including higher volumes of contracted physicians during staff quarantine periods and increased rates of burnout and turnover.

Rebuilding their volunteer pool is among the toughest undertakings facing hospices and a long-standing problem that has been exacerbated by COVID, Gurian said.

There was this problem with reaching the volunteer threshold that was coming before the pandemic, Gurian told Hospice News during a recent Hospice News webinar. I think that process has been exacerbated by COVID, as with many of our workforce challenges. The volunteer problem has just been accelerated by COVID. Hospices will need to adapt more quickly as they try to involve different types of people in volunteering.

The volunteer problem has just been accelerated by COVID. Hospices will need to adapt more quickly as they try to involve different types of people in volunteering.

Mollie Gurian, Vice President of Home Policy and HCBS at LeadingAge

Recruiting a wider demographic

Retired older adults are the most common population to engage in hospice volunteer work, and with more of these individuals reaching the need for hospice care on their own in the coming years, providers will face supply and demand challenges for staff and volunteers mirroring each other, Gurian explained.

Hospices have struggled for many years about how to engage different generations in hospice volunteering and tailor hospice volunteering to the different generational needs of people who are still working, whether they are young people or teenagers, she said.

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

Hospices have also sought partnerships to develop community service projects for volunteers that fall both within and outside the hours of direct patient care, including landscaping work at hospice facilities and assisting with food preparation. for their patient home meal delivery services.

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

It just starts with a kind of innovative approach to thinking about a new generation of volunteers who are engaged for different reasons, Muir said during the webinar. This will then perhaps allow for the creation of a new core of volunteers which could also have an impact on patient direct hours. This is a timely area, great for innovation and creative thinking.

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