Guide
Hospice volunteer requirements under 42 CFR 418.78
Medicare hospices must train volunteers, use them in defined roles under supervision, keep recruiting and retention efforts on record, document the cost savings volunteers bring, and keep volunteer time at no less than 5% of the total patient-care hours of paid staff and contractors (42 CFR 418.78).
What does 42 CFR 418.78 require?
It’s the Medicare Condition of Participation for hospice volunteers. A hospice must use volunteers in defined roles, supervised by a designated hospice employee, and meet five standards.
| Standard | What it asks | What to keep on file |
|---|---|---|
| (a) Training | Orientation and training consistent with hospice industry standards | Curriculum, attendance and dates for each volunteer |
| (b) Role | Volunteers serve in day-to-day administrative or direct patient care roles | A description of each volunteer role and who fills it |
| (c) Recruiting and retaining | Viable, ongoing efforts to recruit and keep volunteers | Recruiting and retention activities, with dates |
| (d) Cost saving | The cost savings volunteers bring, documented | Positions, hours and the estimated cost if paid staff did the work |
| (e) Level of activity | Volunteer time of at least 5% of the patient care hours of paid employees and contract staff | Volunteer hours by type of service, and paid patient care hours |
NHPCO’s summary of the rule adds two practical points. Volunteer services for a patient and family belong in that patient’s plan of care, with the time and services documented. And volunteers who give hands-on care need documented training and a check that they can do the care competently; NHPCO recommends repeating those competency checks regularly.
How is the 5% calculated?
Divide the hours volunteers spent on administrative and direct patient care by the total patient care hours of all paid hospice employees and contract staff over the same period. The result must be at least 5%.
| Item | Hours |
|---|---|
| Paid employees’ patient care hours | 8,500 |
| Contract staff patient care hours | 1,500 |
| Total paid patient care hours | 10,000 |
| Minimum volunteer hours (5%) | 500 |
| Volunteer hours logged (administrative and patient care) | 620 |
| Result: 620 ÷ 10,000 | 6.2%, meets the standard |
The regulation’s text doesn’t fix a measurement period, so choose one and apply it the same way to both sides. Tracking monthly shows a shortfall while there’s still time to recruit. If you count volunteers’ travel or documentation time, NHPCO advises counting paid staff time for the same activities too, so the two sides match.
What counts toward the 5%, and what doesn’t?
Time spent on day-to-day administrative support or direct patient care counts. Fundraising and board service don’t, and neither does other work outside those two categories, however valuable.
| Activity | Counts? | Why |
|---|---|---|
| Companionship, respite and sitting with patients | Yes | Direct patient care |
| Household chores, shopping and errands for patients and families | Yes | Help to patients and families |
| Transportation for patients or families | Yes | Help to patients and families |
| Answering phones, filing, mailings, data entry | Yes | Administrative support |
| Travel, documentation and calls to patients | Can count | Only if paid staff are paid for the same activity and their time is counted too |
| Fundraising events | No | Not administrative or patient care |
| Board service | No | Excluded |
| Crafts such as sewing for patients | No | Valued, but not administrative or patient care |
NHPCO offers a rule of thumb: if a volunteer is doing work you would pay an employee to do, those hours count. Volunteers who provide professional services must meet all the requirements of their specialty, including any state license or registration.
What cost-savings records are needed?
For each position a volunteer fills, record the position, the hours volunteers worked in it and an estimate of what the hospice would have paid employees to do that work (§ 418.78(d)).
CMS gives no standard formula, so each hospice chooses its own method. Two rates fit the rule: the hourly cost of the paid job that matches the position, which follows the regulation’s wording most closely, or Independent Sector’s value of a volunteer hour ($36.14 nationally in its 2026 release), which NHPCO’s guidance points to. Whichever you choose, write the method down and use it the same way every period. A simple log works:
| Column | What goes in it |
|---|---|
| Date | The day the work was done |
| Volunteer | Who did it |
| Position | The volunteer position, matching your role descriptions |
| Type | Administrative or direct patient care |
| Hours | Time worked, including any travel you count for paid staff too |
| Hourly rate | The rate your written method uses for that position |
| Estimated cost | Hours × hourly rate |
How much training do hospice volunteers need?
Federal rules set no minimum number of hours. Training must be consistent with hospice industry standards, and states may add their own rules.
- NHPCO’s tip sheet notes that its Hospice Volunteer Program Resource suggests a 16-hour training program.
- Alaska, for example, requires an orientation of at least four hours specific to hospice services, documented within the first week (7 AAC 12.338).
- Volunteers who give hands-on care need documented training and a competency check before they do that care.
Topics to consider for orientation: the hospice philosophy of care, confidentiality, infection control, boundaries with patients and families, grief and bereavement, what to do in an emergency, and how to record visits and hours. Check your state’s hospice licensure rules; when federal and state rules differ, follow the stricter one.
What records should a hospice keep?
Eight kinds of records cover all five standards. Keep them current every period, not just before a survey.
- A description of each volunteer position And the hospice employee who supervises volunteers.
- Orientation and training records for each volunteer Dates, topics, and competency checks for anyone giving hands-on care.
- Volunteer hours by person and type of service Administrative or direct patient care, for each period.
- Paid patient care hours for the same period Employees and contract staff.
- The 5% calculation for each period
- The cost-savings log and the method behind it
- Recruiting and retention activities, with dates
- Volunteer services in each patient’s plan of care Kept in the hospice’s clinical record, not in volunteer software.
What can Nehemiah track today?
Nehemiah tracks volunteer hours, roles, trainings and their renewals today. A hospice report pack with 5% and cost-savings reports isn’t available yet.
Keep patient information out. Nehemiah manages volunteer records, not patient records. Patient names, care details and plans of care belong in your clinical record system.
Comparing tools for a hospice program? Better Impact’s Volunteer Impact has a dedicated hospice page; see Nehemiah vs Better Impact for a fair look at both.
Running a hospice volunteer program? Tell us what you track
Questions people ask
Do fundraising or board volunteers count toward the 5%?
No. Only day-to-day administrative and direct patient care services count. NHPCO’s summary of the rule says fundraising and board member activities can’t be counted.
Over what period is the 5% measured?
The regulation’s text doesn’t name one. Track it monthly so a shortfall shows up early, review it over the year, and use the same period for volunteer and paid hours.
Can a hospice count volunteer travel time?
NHPCO’s guidance says it can, if the hospice pays employees for the same travel and also counts that paid staff time in the 5% calculation.
Is there a required number of training hours for hospice volunteers?
Not in federal rules, which ask for orientation and training consistent with hospice industry standards. Some states set a minimum: Alaska requires at least four hours of hospice-specific orientation.
What hourly rate should we use for cost savings?
CMS gives no standard formula. One option is the pay for the matching staff position, which follows the rule’s wording. Another is Independent Sector’s value of a volunteer hour ($36.14 nationally), which NHPCO’s guidance points to. Pick one, write it down and use it consistently.