CMS Compliance
HOPE replaced HIS on October 1, 2025. Here's what your agency needs to do.
6 min read
Clinical / Dementia
June 2026 · 10 min read
You already know what FAST 7A looks like. You've sat with those patients — the ones who only say "mama" now, or who quiet when you hold their hand but can't form words anymore. You know it before you score it.
What you might not know is that "FAST Stage 7" — without the substage — is one of the most common reasons dementia claims fail ADR review. Because FAST 7 without a letter doesn't correspond to a specific eligibility criterion. The LCD references substages. Auditors reference substages. Your chart needs to reference substages.
LCD L34538 requires dementia patients to be at or beyond FAST Stage 7A. Stage 7A is defined as speech limited to approximately six or fewer intelligible words during an average day. That's the Medicare threshold. Not Stage 7 broadly. Not Stage 6E, even for a patient who is otherwise profoundly impaired. 7A.
FAST Stage 7 has six substages — 7A through 7F — each representing progressively severe loss. Eligibility starts at 7A. A patient at 6F (loss of continence plus early 7-level changes) doesn't qualify under the dementia criteria. A patient at exactly 7A does. The auditor checking your chart knows this distinction. Your documentation needs to reflect it.
Stages 1–4: Normal aging through mild Alzheimer's. Patients at these stages don't belong on hospice under the dementia criteria and shouldn't be admitted as such.
Stage 5: Moderate Alzheimer's — needs help choosing clothes, may need some grooming assistance. Functional but losing independence.
Stage 6 (A through E): The stage most of your patients pass through before qualifying. 6A is improperly dressing without assistance. 6B is unable to bathe properly. 6C is unable to manage toilet mechanics. 6D is urinary incontinence. 6E is fecal incontinence. A patient at FAST 6E may be completely dependent, doubly incontinent, and profoundly impaired — and still doesn't meet the Medicare dementia threshold.
Stage 7A: Speech limited to ≤ 6 intelligible words during an average day. This is the eligibility threshold.
Stage 7B: Intelligible vocabulary limited to a single word — or no words at all.
Stage 7C: Non-ambulatory without personal assistance.
Stage 7D: Unable to sit up without support; would fall without positioning.
Stage 7E: Unable to smile.
Stage 7F: Unable to hold head up.
Patients don't always progress through these sequentially. A patient can be 7B for speech but 7C for ambulation, and the substages don't have to be in lockstep. Document what you observe, at the substage that matches the observation.
Insufficient:
Patient has advanced dementia. FAST Stage 7. Continues to decline.
An auditor reads this and sees: no substage, no observed verbal output, no secondary condition. Vulnerable.
Defensible:
Patient assessed at FAST Stage 7A. During this 60-minute visit, patient produced two intelligible words ("no" and her daughter's name) in response to direct questions and name calling. All other vocalizations were non-intelligible moaning or repetitive sounds. Patient is non-ambulatory, doubly incontinent, dependent in all ADLs. PPS 20. Secondary condition: 8% weight loss over the past 60 days (132 lbs to 121 lbs), with ongoing dysphagia — family reports patient now tolerates only pureed foods and thickened liquids.
That note maps to the LCD. The auditor can check every box. That's what your chart should read.
LCD L34538 requires a secondary condition for dementia eligibility. A patient at FAST 7A without one is technically not fully LCD-supported, even if the stage is correctly documented.
The most common secondary conditions: recurrent aspiration or aspiration pneumonia; urinary tract infections (recurrent, at least one in the past month); Stage 2+ pressure injuries; weight loss ≥ 10% in the prior 6 months; dysphagia with documented nutritional compromise; or recurrent fever. When one is present, document it explicitly with dates and measurements. "Patient with history of aspiration" is not the same as "patient hospitalized twice in 4 months for aspiration pneumonia, most recently [date]."
Omitting the substage — "FAST 7" in a chart is an invitation for the auditor to determine the substage themselves based on the visit notes. Let them, and they may not choose 7A.
Inflating the stage — documenting 7A when the patient clearly produces more than six words in a visit is a clinical falsification, not a charting choice. If a patient is at 6C and declining toward 7A, document 6C and the trajectory.
Inconsistent staging across visits — 7A on admission and 6E six weeks later, with no explanation. Dementia progression doesn't reverse. Explain any apparent regression.
No secondary condition documented — even if one exists. The chart must record it explicitly, with clinical detail, at least once during the benefit period. Every visit doesn't need it, but the record does.
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