The Home Health Industry is focusing on lasers for a reduction in spending of 6.4% or $1.135 billion, but several other parts of the proposed regulations deserve additional attention and include silver lining.
According to Brian Harris, vice president of financial consulting at Simitree, providers should note that the rate reductions included in CMS' final rules are usually about half of what is usually proposed, and advocacy work can help make a difference.
However, Harris said the cut was “disappointing” during Tuesday's webinar, regardless of the final rules.
“CMS proposes these permanent adjustments each year in the proposed rules, and ultimately cut the time in the final rule in half, especially over the last three years,” commented Harris. “Even if we take a similar approach this year, it is important to note that there is a high chance that spending will be overall reduced, and we are considering this permanent adjustment factor, particularly a 4.059% reduction in rate reduction.
Harris said 2026 was the first year Medicaid implements clawbacks and feels he feels over-reaching Medicaid bills. These temporary adjustments are just over $5.3 billion. According to Harris, home health providers should expect these adjustments to be implemented throughout the 2028 rulemaking period.
According to Simitree, a positive aspect of the proposed final rule is that the CY2026 national visit rate for Home Health Assistant CY2026 rose slightly from CY2025, up from $78.20 to $80.11.
The most notable increase in hourly wages occurred in speech-language pathology, which went from $205.22 to $210.23.
Additionally, changes to wage indexes present a favorable update. In urban areas, the average proposed increase is 0.34%, while in rural areas it is 0.13%. Harris warned that providers who do not submit quality data will face a 2% penalty.
For rural providers, Montana's proposed wage increases are the highest, at 18.48%. Washington state shows its lowest forecast rise at 4%. The Virgin Islands, Idaho, Puerto Rico, Connecticut and Tennessee are all facing a uniform decline of 5% based on the CY2026 PDGM Case Mixweight and Low Use Payment Adjustment (LUPA) threshold.
These proposed fees vary. In Santa Fe, New Mexico, home health aides fell 1.5% between 2025 and 2026, with hourly rates falling from $82.52 to $81.32. Conversely, in Pennsylvania reading, aides experience a 9.1% increase, with interest rates rising from $74.75 to $81.57.
Additional changes
What experts say could be one of the biggest “wins” for providers. This is a proposed change in face-to-face encounters to simplify and “unleash” the growing requirements over the years.
Currently, the CMS allows non-physicians to perform the necessary face-to-face encounters, regardless of whether they are certified practitioners or have previously cared for patients. However, if a doctor met, they had to be certified physicians or they had previously cared for the patient. The CMS suggests removing this restriction, allowing the encounter to be carried out regardless of whether the physician is a certified physician or previously caring for the patient.
“We need to see the collaboration, just like hospitals to doctors,” Jnon Griffin, senior vice president of Simitory, told Home Health Care News. “But with this change, I've almost said that if everyone is somehow related, then they can now introduce you. It makes things much easier for an institution. (Medicare management contractor) I think you'll experience this because Macs have already adopted it.”
Additionally, CMS proposed to remove measures to assess the proportion of patients receiving COVID-19 vaccinations from the Home Health Care Quality Reporting Program (HHQRP). The proposal also calls for information on changing the deadline for submitting data for HHQRP data, and promoting digital quality measurements for HHQRP and new measurement concepts.
Home Health Value-Based Purchasing Programs may also add four new measures: three measures to assess Medicare spending per beneficiary and improved functioning of dressing and bathing patients.
Finally, new and updated provider registration rules have been proposed to reduce inappropriate payments, such as temporary cancellation of provider Medicare enrollment, such as whether the beneficiary has proven that the provider did not provide billing services. The CMS also proposed deactivating the claim privilege of a physician or practitioner if it has not ordered or certified services for 12 consecutive months.
How to prepare
According to Harris, providers should begin preparing for these Cy2026 changes by focusing on coding and OASIS. It is also necessary to assess the actual financial impact of the proposed reductions in each location, taking into account factors other than the universal 6.4%.
The invested parties must also analyze the data and share perspectives, Harris said he emphasized the importance of advocacy work to ease the hit of the proposed final rule. However, he warned that even with advocacy, providers can expect an overall decline in spending.
“History shows that the CMS dialed a bit with the final rule compared to the proposed rules. It only happens through advocacy. That's not something we can expect to sit down and do this,” Harris said. “From August 30th, 60 days after the rules were announced, the advocacy I believe is important to get a dialback to CMS and to fully understand the impact this 6.4% reduction in spending will have on institutions.”
