For home health agencies, the CY 2027 Home Health Proposed Rule (CMS-1844-P) is, first and foremost, a quality-program story. Yes, it sets next year's payment rates, and we'll cover that up front because you'll want the headline number. But the developments most likely to shape how you plan sit in the quality reporting sections: what CMS is confirming for the Home Health Quality Reporting Program (HH QRP) and the Expanded Home Health Value-Based Purchasing (HHVBP) model, and how the agency is signaling it may eventually connect the two.

That's also where this rule gets tricky. Alongside a handful of confirmed changes, CMS has folded in a list of "alignment opportunities" it is explicitly not accepting comments on, and it points to an outside expert-panel report for still more possibilities. Much of what's circulating online blends the rule's actual text with that outside report. This post sorts it out: what the rule confirms, what's still just an idea, and what to check in your own numbers this week.

First, the Payment Update

Medicare home health payments would rise 2.4% overall in CY 2027. The net figure breaks down as follows:

One detail worth flagging: since 2020, when Medicare moved to PDGM, CMS has adjusted rates each year based on whether agencies changed their billing behavior the way the agency predicted. This year, for the first time in three years, CMS is not proposing a new permanent rate cut tied to that behavioral check. A temporary reduction to recover money from prior years is still on the table, but there is no new permanent cut this cycle.

That's the rate picture. The rest of this rule, and the rest of this post, is about your quality programs.

What the Rule Actually Confirms

These are real proposed changes written into the rule itself. Treat them as things to prepare for now.

Reporting periods move to a standard calendar year. Today, OASIS and HHCAHPS are tracked on two different, oddly timed 12-month windows. This rule would align both to January 1–December 31. It's the one confirmed change that genuinely simplifies your reporting calendar. The transition phases in over three years, beginning with CY 2027 for the January 2029 Annual Payment Update (APU).

New HH QRP submission deadlines. Starting with the 2027 reporting year, submission windows tighten from four-and-a-half months to 45 days.

Updates to appeals processing. Intended to speed up digital paperwork during reconsiderations, when your agency disputes a payment penalty.

A Request for Information (RFI) on future quality measures. This isn't a policy change. CMS is asking the industry for input, and it signals where the agency's attention is heading next. Comments on CMS-1844-P are due August 31, 2026.

What's Still Just an Idea

The rule also includes a list of "alignment opportunities": ways CMS might eventually connect HH QRP and HHVBP more closely. This list appears in the rule text, but CMS is explicit that it's for background only and is not accepting comments on it. In practice, that's the agency's way of saying it isn't ready to propose these yet. On the list:

• Aligning the quality measures used in HH QRP and HHVBP more closely
• Syncing the timing of your Interim Performance Report with your Star Rating updates
• Aligning appeals timing across both programs
• Tying QRP compliance and quality scores directly into your HHVBP payment score

If any of these become real proposals, expect them in next year's rule (CY 2028), not this one.

What the Expert Panel (TEP) Report Adds

The rule points to a Technical Expert Panel (TEP) that CMS convened in December 2025 specifically to discuss HH QRP and HHVBP alignment. The panel's findings are not part of the rule itself. Two things in that report are worth knowing.

Already on track. CMS has said it plans to add two measures to your Quality of Patient Care Star Rating by CY 2027. This is a settled plan, not an open question.

Still genuinely speculative. The panel also discussed a further round of measure changes on top of those two planned additions:

• Possibly added: Improvement in Bathing, Improvement in Upper Body Dressing, and Improvement in Lower Body Dressing
• Possibly removed (only if the Discharge Function Score goes in first): Improvement in Bed Transferring and Improvement in Ambulation/Locomotion. The reasoning: once the Discharge Function Score is in place, these would effectively measure mobility twice.

A possible new Star Rating. The panel also weighed adding a composite "Overall" Star Rating alongside your two existing ones (Quality of Patient Care and Patient Survey). The panel leaned toward adding a third rating rather than replacing both with a single combined number, mainly to avoid confusing patients and families who compare agencies.

None of this is proposed rule language. It's expert input CMS is weighing, cited as context.

Why This Distinction Matters

Your HHVBP payment adjustment reflects performance from roughly two years ago, while your QRP penalty is based on much more recent data. Same patient assessments, two different clocks. The calendar-year alignment above is a confirmed step toward making those clocks less confusing. Everything else on the alignment list would tie your quality reporting and your HHVBP payment far more tightly together. That's a much bigger operational shift than a calendar change, which is exactly why it's worth not treating a maybe as a certainty.

What to Do Now

Review your OASIS and HHCAHPS reporting calendar. If your team still tracks the old split-year windows, start planning the shift to a standard calendar year.

Check your QRP compliance threshold. The calendar shift changes your review timing. Make sure someone owns catching that before it causes a problem.

If you plan to comment, start drafting this week. The alignment list isn't open for comment, but the RFI on future quality measures is. That's your opening to shape next year's rule instead of reacting to it later. Comments are due August 31, 2026.

How SHP Can Help

The agencies that navigate this rule best are the ones already watching their quality numbers closely. SHP for Agencies gives home health providers real-time visibility into the metrics this rule touches:

• HHVBP Total Performance Score tracking and cohort percentile ranking, including our VBP Preview 2026+ report
• Quality of Patient Care and Patient Survey Star Rating trending
• OASIS and HHCAHPS reporting aligned to your submission deadlines

As CMS moves toward a final rule, that visibility is the difference between reacting to a measure change and seeing it coming.

Current SHP customers: contact your Senior Account Manager or Client Success representative to learn more. Not yet an SHP client? Connect with our team to see how SHP can support your quality strategy.