Snapshot
HCHB’s 2027 Medicare Advantage comment letter supports CMS’s broader goals but argues that Medicare Advantage policies still create major barriers to timely home-based care through inconsistent prior authorization, weak continuity protections, and quality incentives that do not fully account for the needs of medically complex patients. The letter urges CMS to require faster and more standardized electronic prior authorization, preserve meaningful accountability for appeals and SNP care management, retain or replace the EHO4ALL reward, and develop better visibility into home health access within Star Ratings, noting concerns such as referral-to-start-of-care delays and wide variation in plan behavior. Overall, the document positions home-based care as a clinically effective and cost-efficient setting that CMS should protect more deliberately through clearer access rules, smarter quality measurement, and more transparent Medicare Advantage oversight.