In 2025, the Coalition advanced meaningful policy progress across multiple fronts despite a significantly shifting policy landscape. We strengthened our impact with CMS by shaping key demonstrations and securing recognition of our recommendations in final regulations. At the state level, Medicaid programs continued to pursue waivers and state plan amendments to expand services for older adults and individuals with serious illness.
Amid a challenging Congressional environment, we sustained bipartisan engagement with policymakers—grounded in evidence that improving care for people with serious illness enhances quality while addressing costs.
We are building on this momentum and remain confident that our collective cause will continue to resonate across the aisle.
Elevating Patient and Caregiver Voices in Medicare Policy
Every proposed Medicare regulation presents an opportunity to shape policy—and in 2025, we ensured the voices of patients and caregivers were heard. Despite a shifting Administration environment, rulemaking timelines remained intact, and public comments were both accepted and meaningfully acknowledged.
C-TAC submitted comments on 11 proposed rules, many of which included Requests for Information on critical topics such as well-being, physical activity, and nutrition. This engagement allowed us to influence policy before finalization—and in most cases, the areas we supported were adopted as proposed.
Notably, our input was recognized in more than half of the final rules, with several comments quoted verbatim. Importantly, even where we raised concerns or opposed proposals, our perspectives were acknowledged—demonstrating the growing impact of our advocacy.
Key Regulatory Impact Highlights
Medicare Physician Fee Schedule
- Secured adoption of all supported provisions
- Advanced integration of palliative care and advance care planning into the heart failure component of the Ambulatory Specialty Model
- Promoted inclusion of “Felt Heard and Understood” across Medicare measure sets
- Elevated concerns regarding the removal of social determinants of health risk adjustment and the Health Equity Adjustment to ACO quality scores—both acknowledged by CMS
Home Health Rule
- Achieved finalization of supported provisions
- Influenced policy on face-to-face requirements, with CMS citing our recommendation to improve workforce flexibility, team-based care, and resource allocation—particularly in rural and complex care settings
End-Stage Renal Disease (ESRD) Rule
- Secured adoption of supported policies
- Advanced a more holistic definition of wellness—encompassing mental, physical, social, emotional, spiritual, and financial domains—recognized by CMS
- Raised concerns about the removal of Social Drivers of Health measures, reinforcing the link between systemic inequities and patient outcomes
Skilled Nursing Facility (SNF) Rule
- Advanced adoption of supported policies
- Elevated well-being as a future measurement priority, emphasizing whole-person care and alignment with patient goals
- Advocated for inclusion of palliative care within SNF quality measures and for adaptable, patient-centered metrics
- Highlighted concerns around removing the Health Equity Adjustment, urging CMS to consider alternative approaches for vulnerable populations
Hospital Inpatient Rule
- Secured finalization of supported provisions
- Advanced development of patient-centered measures that reflect the full spectrum of well-being, including emotional, social, and physical health
- Promoted measures that strengthen care transitions, patient activation, and goal-aligned care pathways
Advancing Innovation Through CMMI Demonstrations
As a longstanding partner to the CMS Innovation Center (CMMI) since its inception, we continue to shape and advance models that deliver patient-centered, high-quality care for individuals with serious illness and their caregivers. Building on progress across multiple Administrations, we have helped drive the integration of advance care planning, expand access to palliative care alongside curative treatment, and promote flexibilities that address both medical and social needs.
In 2025, CMMI further elevated serious illness care as a core priority across its portfolio. Key areas of progress include:
- Elevating the needs of high-risk, complex populations within risk-based payment models, including continued investment in the High-Needs track of ACO REACH and its evolution into the ACO LEAD model
- Expanding support for individuals living with dementia and their caregivers through the GUIDE Model, which introduces enhanced care coordination and respite services
- Advancing coordinated, accountable care for kidney disease populations through the Kidney Care Choices model, aligning providers around improved outcomes and total cost of care for individuals with CKD and ESRD
Shaping Federal Policy and Turning Advocacy into Impact
Working alongside our Congressional champions, we:
- Redrafted the Improving Access to Advance Care Planning Act (S.4873/H.R.8840) to address CMS technical concerns and advance its path forward
- Shaped and supported the Hospice CARE Act, contributing policy expertise to strengthen accountability and quality in hospice care
- Successfully advocated for a two-year extension of Medicare telehealth flexibilities, expanding access to advance care planning and enabling hospice recertifications via telehealth
- Led Capitol Hill briefings to educate policymakers on the ACO REACH Model and innovative approaches to improving kidney care
- Advanced the national dialogue on palliative care through a major fall convening of cross-sector leaders, building momentum for expanded access to community-based services
- Supported and advanced key legislation to expand access, workforce capacity, and quality of care, including the Expanding Access to Palliative Care Act (S.1845), Provider Training in Palliative Care Act (S.2117), Compassionate Care Act (S.4949), and Palliative Care and Hospice Education and Training Act (S.2243)
Driving State Policy Action & Innovation
By leveraging state plan amendments (SPAs) and waivers, states are actively expanding services for older adults and individuals with serious illness—while setting national precedents with CMS that accelerate adoption across the country. Key actions include:
- Integrating Area Agencies on Aging into dual alignment initiatives to strengthen home and community-based services (Ohio)
- Authorizing reimbursement for community health workers to deliver care coordination and address social drivers of health
- Enabling registered nurses to bill independently for care coordination and enhanced case management services (Oregon)
- Establishing a new licensure pathway for pediatric palliative care homes, paving the way for distinct reimbursement outside of hospice (Iowa)
- Advancing recognition of palliative care as a preventive service through the Center for Medicaid and CHIP Services (CMCS), creating opportunities to move care upstream
- Expanding reimbursement pathways for palliative care, including comprehensive assessments delivered by interdisciplinary providers
- Increasing access to pediatric palliative care through targeted waiver strategies and program expansion
