Federal Home Health Update
(July 15, 2025) Please find below the most recent updates from LeadingAge National for home health providers:
CMS Releases Yet Another Devastating Home Health Proposed Rule. On June 30th, the Centers for Medicare and Medicaid Services (CMS) released the Calendar Year (CY) 2026 Home Health Proposed Rule that will make an aggregate -6.4 percent cut to the base payment. CMS is proposing a -4.059 percent permanent adjustment to the CY 2026 home health base payment rate. Additionally, the temporary adjustment which has been accruing over the last several years now stands at $5.3 billion. If this were to be taken back in a single year, it would be a 35 percent reduction to the base payment, which CMS considers too much of a burden. Therefore, CMS is proposing to apply the first temporary adjustment in CY 2026 with an additional -5.0 percent on top of the proposed -4.059 permanent adjustment. The minuscule market basket update for CY 2026 is proposed at only 3.2 percent. The estimated aggregate decrease is -6.4 percent, or -$1.135 billion. Coupled with the -8.79 percent cut to the baseline since CY 2023, if this rule goes into effect, LeadingAge National believes that this will threaten the very existence of nonprofit, mission-driven home health. Between 2019 and 2023, the number of skilled home health agencies that treated more than 10 fee-for-service patients annually decreased or remained the same in 94.1 percent of U.S. counties. These are concerning statistics considering the growth in the older adult population and the focus on receiving care in the home. In addition to the devastating cuts, the rule includes removal of several measures in the Home Health Quality Reporting Program, Home Health Value-Based Purchasing (HHVBP) quality measure set, and changes to the Conditions of Participation regarding all-payer Outcome and Assessment Information Set (OASIS) collection.
LeadingAge National has analyzed the portions of the rule relating to home health payment, quality reporting, and HHVBP for members here.
Senators Ask CMS Not to Cut Home Health. U.S. Senators Susan Collins (R-ME) and Marsha Blackburn (R-TN) sent a letter to CMS Administrator Dr. Mehmet Oz raising concerns about the future of the home health benefit and asking CMS to use their statutory authority to pause any planned cuts in the CY 2026 Home Health Proposed Rule, which is currently under review with CMS. Both senators have been champions of home health for many years, especially for their rural communities which are losing access to these services in increasing numbers. LeadingAge National appreciates the senators' support and advocacy on behalf of home health providers and will continue its advocacy to prevent additional cuts in CY 2026.
CMS Posts Home Health Preview Reports for October 2025. The CMS Home Health Agency Provider Preview Reports and Star Rating Preview Reports are updated and available on the Internet Quality Improvement and Evaluation System (iQIES). The performance scores for quality measures in the report will be published on the Care Compare tool in the October 2025 refresh. Data contained within the Provider Preview Reports are based on OASIS assessment data submitted by agencies from Quarter 1, 2024 through Quarter 4, 2024. Additionally, data for the claims-based measures related to HHVBP will display data from Quarter 1, 2023 through Quarter 4, 2024 for the Discharge to Community and Quarter 1, 2024 through Quarter 4, 2024 for the Home Health Within-Stay Potentially Preventable Hospitalization measure. The data for the Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) measures will display data from Quarter 2, 2024 through Quarter 1, 2025. Providers have until Aug. 8, 2025 to review their performance data.
Updated Quarterly OASIS Q&As. CMS released July 2025 OASIS Questions and Answers (Q&As). This document is updated on a quarterly basis and is intended to provide guidance on OASIS questions that were received by CMS help desks.
As a reminder, responses may be time-limited and may be superseded by future CMS guidance. On July 1, 2025, the requirement for all-payer OASIS data collection went into place, which means, with few exceptions, every patient served by a home health agency must have an OASIS conducted regardless of their payer source. In this new quarterly Q&A, CMS makes several key clarifications. First, CMS clarifies that if none of the services authorized by an individual's insurance are "skilled," per Chapter 7 of the Medicare Benefit Policy Manual, then the patient does not need an OASIS assessment. Second, skilled outpatient therapy conducted by a Medicare-certified home health agency under Part B services requires an OASIS assessment. Third, occupational therapy (OT)-only services are considered skilled services, and patients receiving those services regardless of payer would need an OASIS. Other Medicare-specific coverage criteria such as homebound status or OT services establishing eligibility which may be waived by another payer are not considered when identifying if an OASIS is required. In addition to these all-payer OASIS clarifications, the Q&A covers questions on Medicare Advantage (MA) to Traditional Medicare transitions, mobility assessments, fluid diet coding, and tracheostomy care coding.
LeadingAge National Supports New CMS Data Collection on MA Prior Authorizations and Payments. LeadingAge National, along with its post-acute care (PAC) coalition partners, submitted a comment letter to the Office of Management and Budget (OMB) on a final notice of a pending CMS data collection initiative that will require MA plans to begin reporting service-level data on prior authorizations and claims payments. LeadingAge National and its PAC coalition partners have been advocating for this essential data to be reported. It will not only help show the volume of prior authorizations and concurrent reviews, but will also help identify which services are being denied the most as well as the outcomes of any appeals. CMS indicates that it will use this data for oversight and enforcement activities. LeadingAge National hopes, in turn, that it will drive greater MA plan compliance with MA, and applicable Medicare, regulations related to Part A and B service coverage. The comment letter is available here.
LeadingAge National Pushes CMS to Ensure that PAC Providers Benefit from Future MA Prior Authorization Reforms. LeadingAge National, along with its PAC coalition partners, shared providers’ pain points on current MA prior authorization practices with CMS Principal Deputy Director for the Center of Medicare Alec Aramanda and Senior Medicare Policy Advisor Joe Albanese on July 10th. Their remarks focused on the administrative burden to PAC providers resulting from the lack of standardization across MA plans, timeliness of plan decisions, and the volume and frequency of the requests providers must make to ensure that beneficiaries receive needed care. They inquired whether PAC services could be expected to benefit from the recent insurer promises of prior authorization reforms to reduce, standardize, and speed up decision making and whether the Interoperability and Prior Authorization rule that was finalized in 2024 and included provisions around shortening prior authorization timeframes and deploying Applicable Programming Interfaces to create essentially an electronic prior authorization process would indeed bear fruit for PAC providers like skilled nursing facilities (SNFs) and home health agencies. While CMS engaged in the discussion and LeadingAge National's proposed solutions on the topics, they offered few clear answers to their questions about how the plans’ reform proposals and the rule would be applied to PAC services. However, CMS staff showed interest in the solutions offered. LeadingAge National encouraged them to standardize prior authorization requests across all MA plans, including requiring the same information fields. They suggested that all prior authorizations for PAC services should automatically be treated as expedited requests with an expectation of a 24-hour turnaround time, and they pressed for the Trump CMS to offer concrete guidance on what “course of treatment” means for PAC services, as the MA rules require that prior authorizations must cover an entire course of treatment. LeadingAge National's hope on the last recommendation is to reduce the need for subsequent requests by ensuring that the initial authorization covers a longer period of care that corresponds to the needed services. In the end, all agreed to meet again to dig deeper into the proposed solutions, and in the interim, LeadingAge National will share more details and information on the proposed solutions with Mr. Aramanda and Mr. Albanese. They indicated that they will also make sure that this information is shared with the internal CMS workgroup charged with implementing the Interoperability and Prior Authorization rule and Chris Klomp, who is the director of the Center for Medicare and oversees the MA program. CMS also said that they will look to answer the technical questions previously submitted about how these new reforms will benefit PAC providers. The coalition views this as a positive first meeting and will continue its work to educate the CMS staff on how MA prior authorization practices impact providers and those they serve.
Contact: Meg Everett, meverett@leadingageny.org