The government shutdown delayed the CY 2026 Medicare Home Health PPS Final Rule (CMS-1828-F) by nearly a month, but the long-awaited announcement was added to the Federal Register on November 28th. We reviewed and highlighted key elements of the final rule to help agencies plan for 2026.
The Final Rule Summarized
The overall economic impact related to the changes in payments under the HH PPS for CY 2026 is estimated to be -$220 million (-1.3 percent). This reduction is the result of combining the following payment updates:
- A home health payment update percentage of +2.4 percent ($405 million increase)
- A permanent adjustment of -0.9 percent ($150 million decrease)
- A temporary adjustment of -2.7 percent ($460 million decrease)
- A Fixed Dollar Loss (FDL) decrease of -0.1 percent ($15 million decrease)
Payment Update Nuances
The calculation of the final rule’s impact is complicated by differences in how the payment adjustments are applied. For example, the estimated -0.9 percent decrease and the -2.7 percent decrease related to the finalized behavior assumption adjustments includes all payments, while the finalized -1.023 percent permanent adjustment and the -3.0 percent temporary adjustment only apply to the national, standardized 30-day period payments and does not impact payments for 30-day periods that are LUPAs.
Final Rule Financial Highlights
Regulatory experts at Homecare Homebase identified essential components that will have the greatest financial impact on providers.
- Payment rate – updated the national standardized 30-day period payment rate to $2,038.22
- Per-visit payments – the national per-visit payment amounts are now home health aides ($80.12), medical social services ($283.64), occupational therapy ($194.74), physical therapy ($193.42), skilled nursing ($176.96) and speech-language pathology ($210.25)
- LUPAs and Functional Impairment – the LUPA add-on factors are 1.7200 for skilled nursing (SN), 1.6225 for physical therapy (PT), 1.6696 for speech-language pathology (SLP) and 1.7238 for occupational therapy (OT). LUPA thresholds and functional impairment levels were updated using 2024 claims data, shifting LUPA thresholds for 18 payment groups by one visit
- Fixed dollar loss (FDL) – the FDL ratio for outlier payments is now 0.37
- Wage Index – the 2026 wage index maintains a previous five percent cap on wage index decreases
- Case-mix weights – new case-mix weights were recalibrated using CY 2024 home health claims that were linked with OASIS data
- Comorbidity adjustment – adjustments were made to the comorbidity adjustment subgroups using the latest claims data. The subgroups now include 20 low comorbidity adjustment subgroups and 98 high comorbidity adjustment subgroups
Final Rule Operational Highlights
The final rule includes updates that will have a significant impact on operations and compliance processes. These highlights include:
- Face-to-Face (F2F) encounters – moving forward, any allowed practitioner (physician, NP, PA, CNS, CNM) may perform the Face-to-Face (F2F) encounter, regardless of whether they are the certifying practitioner or whether they care for the patient in the acute or post-acute facility from which the patient was directly admitted to home health and who is different from the certifying practitioner
- Conditions of Participation (CoP) clarifications – technical changes were made to the CoPs to further clarify that all patients receiving skilled services, regardless of payer, are subject to OASIS submission. These changes also align language with the requirements finalized in the CY 2023 and CY 2025 HH PPS final rules
- Reconsideration extensions – agencies can now request a reconsideration extension to challenge a finding of non-compliance with home health quality reporting program data submission requirements. These requests can be made if the agency can demonstrate that extraordinary circumstances such as cyber-attacks, hurricanes, earthquakes and other events prevented the organization from meeting the original deadline
- Quality Reporting Program (QRP) measures – the CY 2026 HH QRP now includes 19 measures between OASIS, claims and HHCAHPS measures. One COVID-19 related measure was removed along with four social determinants of health (SDOH) items
- Public reporting updates – providers are given a period of time to submit and correct assessment data before it becomes publicly available. CMS summarized stakeholder input on a change to the final submission deadline period from 4.5 months to 45 days. CMS believes accelerating this deadline could improve the timeliness of public reporting
- HHCAHPS survey and HHVBP measures – new questions were added to the survey to expand on family support and care personalization, while others were removed. The summary star rating calculation was adjusted to incorporate a revised survey structure. In addition, three measures were removed and replaced with four new measures. Measure weights were adjusted, and a new removal factor was added as well
- Provider enrollment – CMS finalized Medicare provider enrollment provisions that modify grounds for denying, revoking or deactivating enrollment and expand the reasons for which CMS can apply retroactive effective dates for provider and supplier revocations
- Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) – CMS tightened accreditation and oversight, clarified prior authorization exemption processes and refined the competitive bidding program
- Deadline confirmation – CMS confirmed that the updates will apply starting January 1, 2026
Access the Resources
Need additional details? Agencies can view CMS’ resources supporting the final rule here:
What’s Next?
After the release of each final rule, Homecare Homebase’s Product Management team applies all necessary updates to the software required for our customers to retain compliance. Meanwhile, the HCHB Analytics team updates our Home Health Impact Model so each customer can see how the new regulations will affect their agency based on their specific claims data.
HCHB is committed to helping agencies successfully navigate the complexities associated with regulatory and industry changes through continued communication with our customers, thought leadership and advocacy on behalf of the home health industry.
