The Centers for Medicare & Medicaid Services (CMS) recently released the CY 2026 Home Health proposed rule on June 30, 2025, introducing some major changes that Home Health Agencies (HHAs) are now reviewing and preparing to comment on. This rule proposes the largest payment cut since the Home Health Agency Prospective Payment System (HHA PPS) began in CY 2000. CMS is suggesting a reimbursement cut of 6.4%, or $1.135 billion.
These cuts stem from the assertion by CMS that HHAs received overpayments due to behavioral changes following the transition from the 60-day episodic PPS payment model to 30-day periods of care under the Patient-Driven Groupings Model (PDGM) in CY 2020. While CMS has applied prospective permanent adjustments since CY 2023, this is the first time CMS has proposed retrospective temporary payment adjustments for perceived overpayments since PDGM's inception. This move could devastate HHAs, especially since nearly half of all agencies already show negative overall margins.
In another development, though anticipated for some time, CMS is looking to update and shorten the Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) survey. CMS proposes reducing the number of questions from 35 to 30 (adding 3 and removing 8), starting with the April 2026 sample month. The proposed changes are as follows:
- Addition of three new questions to assess additional topics of importance to patients:
- Whether the care provided helps the patient take care of their health.
- Whether the patient’s family/friends receive sufficient information and instructions.
- Whether the patient feels the staff cares about them "as a person."
- Consolidation of six questions related to medication management into two questions.
- Removal of three questions regarding which type of staff are involved in caring for the patient.
- Removal of the question asking whether the patient received information about the types of care and services they would get when they first started home health care.
- Minor text changes to some of the existing questions in order to help clarify the question or response options.
Unlike the CAHPS Hospice survey, CMS is not recommending a web-mode option with these changes. However, these modifications significantly alter the questions making up the three current composite measures. As a result, these measures will be removed from public reporting and star ratings until CMS has four quarters of data in October 2027. Until then, the star rating and scores will only reflect the Overall Rating and Willingness to Recommend measures.
One direct consequence of the HHCAHPS changes is the impact on the HHVBP Expanded Model. The revised survey questions will change how the three composite measures (Care of Patients, Communications between Providers and Patients, and Specific Care Issues) are calculated. These three composites are currently used in the model and will need to be removed starting in CY 2026 since the baselines will be materially different. While these measures could be added back once a full year of data is available, this would not be until CY 2027.
CMS also proposes adding four new measures to the HHVBP measure set starting in Performance Year (PY) 2026:
- Medicare Spending Per Beneficiary Post-Acute Care (MSPB-PAC)
- Improvement in Bathing (based on OASIS item M1830)
- Improvement in Upper Body Dressing (based on OASIS item M1810)
- Improvement in Lower Body Dressing (based on OASIS item M1820)
This marks the third update to the measure set since the Expanded HHVBP model began in PY 2023. CMS states that the Achievement Threshold and Benchmarks for the new measures will be shared in the October 2025 IPRs.
Regarding MSPB-PAC, CMS notes, "We anticipate that adding the MSPB-PAC measure will create incentives for greater care coordination to deliver high-quality care at a lower cost to Medicare and incentivize providers to find efficient ways to address patients’ care needs." It seems somewhat counterintuitive to have cost as a quality measure, as it might create incentives to reduce care.
Although MSPB-PAC has been part of the Home Health Quality Reporting Programs (HH QRP) since 2019, it is not a score many HHAs actively monitor. Data from the April 2025 HH Care Compare shows 8,593 agencies with scores (out of 12,069), reflecting the following distribution:
These scores represent the risk-adjusted Medicare spending of a home health agency’s MSPB-PAC HH episodes, relative to the Medicare spending of the national median home health agency’s MSPB-PAC HH episodes across the same performance period. Costs include most Medicare Part A & B payments up to 30 days after a home health episode ends.
The HHVBP measure weighting also needs to change due to the updated measure set. The current proposal shifts the weighting for OASIS/Claims/HHCAHPS category percentages for the larger-volume cohort from 35/35/30 to 40/40/20, as reflected in this table:
| Measure | CY 2025 Measure Weights | Proposed Measure Weights | ||
|---|---|---|---|---|
| Larger-Volume Cohort | Smaller-Volume Cohort | Larger-Volume Cohort | Smaller-Volume Cohort | |
| Improvement in Dyspnea | 6.00% | 8.57% | 7.00% | 8.75% |
| Improvement in Management of Oral Medications | 9.00% | 12.86% | 11.00% | 13.75% |
| Discharge Function Score (DC Function) | 20.00% | 28.57% | 15.00% | 18.75% |
| Improvement in Bathing | - | - | 3.50% | 4.38% |
| Improvement in Upper Body Dressing | - | - | 1.75% | 2.19% |
| Improvement in Lower Body Dressing | - | - | 1.75% | 2.19% |
| Sum of OASIS-based Measures | 35.00% | 50.00% | 40.00% | 50.00% |
| Home Health within-stay Potentially Preventable Hospitalization (PPH) | 26.00% | 37.14% | 15.00% | 18.75% |
| Discharge to Community – Post Acute Care (DTC-PAC) | 9.00% | 12.86% | 15.00% | 18.75% |
| Medicare Spending Per Beneficiary- Post-Acute Care (MSPB-PAC) | - | - | 10.00% | 12.50% |
| Sum of Claims-based measures | 35.00% | 50.00% | 40.00% | 50.00% |
| Care of Patients | 6.00% | 0.00% | - | - |
| Communication Between Providers and Patients | 6.00% | 0.00% | - | - |
| Specific Care Issues | 6.00% | 0.00% | - | - |
| Overall Rating of Home Health Care | 6.00% | 0.00% | 10.00% | 0.00% |
| Willingness to Recommend the Agency | 6.00% | 0.00% | 10.00% | 0.00% |
| Sum of HHCAHPS Survey-based measures | 30.00% | 0.00% | 20.00% | 0.00% |
| Sum of All Measures | 100.00% | 100.00% | 100.00% | 100.00% |
CMS is also proposing to remove the COVID vaccine assessment item and measure. While the OASIS item will still need to be completed through April 2026, the last update on HH Care Compare will be on the January 2026 refresh. Additionally, CMS plans to remove the four social determinants of health that were scheduled to be part of the HH QRP for CY 2027.
One helpful proposal relates to the Face-to-Face (F2F) encounter. After hearing feedback from many providers, CMS proposes allowing physicians, in addition to NPs, CNSs, and PAs, to perform the F2F encounter, regardless of whether they are the certifying practitioner or whether they cared for the patient in the acute or post-acute facility and are different from the certifying practitioner.
CMS has set August 29, 2025 as the deadline to submit comments regarding the proposed rule. The National Alliance for Care at Home "Alliance" has been conducting roundtables over the last two months to solicit feedback and share common positions regarding the rule. SHP plans to comment on the excessive nature of the rate cuts.
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