SFP Graduation Criteria

SFP graduation (completion) criteria are the standards a hospice must meet to exit the Special Focus Program: returning to and maintaining substantial compliance over an 18-month period without serious deficiencies. A hospice that cannot meet them is placed on a termination track. (As of August 2026, the SFP remains paused and the associated litigation stayed; these criteria are as finalized rather than in active operation.)

Under the framework finalized in the CY2024 Home Health rule and detailed in the SFP User's Guide (January 8, 2025), a hospice participates in the SFP for an 18-month period ^[1]. To complete the program, the hospice must not be triaged at an immediate-jeopardy or condition level within that 18-month window and must return to substantial compliance with all requirements ^[2].

The failure path is explicit: a hospice that fails any survey during the 18-month period by having uncorrected condition-level deficiencies and does not return to substantial compliance is placed on a termination track and considered for termination from the Medicare program ^[2]. Graduation is therefore not a scored average but a compliance test sustained across surveys over 18 months.

Graduation is binary: a single uncorrected condition-level deficiency during the 18-month window moves a hospice from the improvement track to the termination track, regardless of progress elsewhere. The criteria reward sustained substantial compliance across all surveys in the window rather than isolated clean visits followed by backsliding. Because the failure endpoint is potential Medicare termination, the SFP period is structurally a make-or-break 18 months for any designated hospice. Condition-level findings during the window are eligible for Informal Dispute Resolution, which provides the only formal mechanism to challenge a deficiency before it becomes part of the compliance record.