Home health reforms continue with major programming and reimbursement changes outlined in the Calendar Year (CY) 2026 Home Health Prospective Payment System (PPS) final rule. Providers seeking success will face new challenges related to the Home Health Consumer Assessment of Healthcare Providers and Systems (CAHPS®) survey and the Home Health Value-Based Purchasing (HHVBP) Model, with significant reimbursement cuts occurring simultaneously. The result is a home health landscape considerably different from what most of us operated under during the PPS and early Patient-Driven Groupings Model (PDGM) era.

Nationally, most HH providers were focused on the proposed >6% cuts, and how that may affect everything from programming operations to episodic margins. When traditional operations and programming approaches fail to deliver under PDGM and in areas such as VBP and HHCAHPS, many providers find themselves behind the eight ball in terms of episodic margins. This instability threatens the financial viability of numerous HH agencies and hampers their ability to continue on their current care path. Currently, nearly half of all HH providers have negative overall margins.

In addition to the payment cuts, HHCAHPS changes will impact VBP and potential bonuses for qualifying agencies. The effect of these changes is to further evolve VBP scoring and baselines, potentially further limiting providers who would qualify for the bonus. In addition, changes to PDGM specifics, including LUPAs, Case-Mix, FILs, Comorbidities, Wages and per Visit Payment rates can all compromise the fiscal bottom line of Home Health agencies. Many of the 2026 Final Rule changes are similar to regulatory changes installed by MedPAC for ALL Part A providers across the care continuum. Other changes seek to further evolve the Volume-2-Value shift mandated by the IMPACT ACT and installed through PDGM.

HH Agencies choosing to rewire operations to address ALL the reforms: PDGM, VBP, V2V programming, HHCAHPS, and care standardization, may find themselves in a group of providers with improved clinical and fiscal outcomes. By adapting care development and delivery protocols from Medicare Part A providers outside of Home Health, agencies regularly report improved clinical results and margins that improve up to 30-40%. These agencies have drilled down on all elements of current HH regulations, and as a result, produce qualified, denial-proof HH episodes that qualify for the VBP bonus.

This progressive webinar series walks you through all the contemporary HH changes in the 2026 Final Rule, discusses rationale for the changes, outlines Operational changes to make for PDGM/VBP success, and presents Case Study demos of HH providers who are on the path to ongoing HH success with improved financial margins. Sign up today and align your care quality with improved financial margins!!

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.

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)

Proposes an overall economic impact of -$1.135 billion (-6.4%).

• Proposes updates to:
  • LUPA thresholds
  • Case-Mix Weights
  • Functional Impairment Levels
  • Comorbidity Adjustment Subgroups
  • Wage Index
  • FDL Ratio
  • 30-Day Period Payment Rate ($1933.61)
  • Per-Visit Payment Rates

Proposes updates to OASIS data collection rules to clarify they apply to all patients receiving skilled care, not just Medicare beneficiaries.

For the CY 2026 HH PPS proposed rule, using CY 2024 claims and the finalized methodology, CMS determined that Medicare still paid more under the new system than it would have under the old system. Therefore, we are proposing an additional permanent adjustment of -4.059% to be made to the 30-day base payment rate. This proposal would continue to satisfy the statutory requirements at section 1895(b)(3)(D)(ii) of the Act to offset any increases or decreases on the impact of differences between assumed behavior and actual behavior changes on estimated aggregate expenditures, reduce the need for any future large permanent adjustments, and help slow the accrual of the temporary payment adjustment amount. The proposed permanent adjustment is also anticipated to lessen any potential temporary adjustment(s) in future years.