(Alexandria, VA)— The National Alliance for Care at Home (the Alliance) today responded to the Centers for Medicare & Medicaid Services (CMS) calendar year (CY) 2027 Home Health Prospective Payment System final rule. The payment update finalized by CMS offers greater stability amid a challenging operating environment, yet the Alliance remains concerned that the finalized 3% temporary payment adjustment may undermine providers’ ability to deliver care in the home. The Alliance is also alarmed that broad provider enrollment provisions may have unintentional consequences for legitimate providers.
The Alliance appreciates that CMS has finalized a projected 2.4% ($415 million) increase, the highest payment update in nearly two decades outside of 2022. This is a constructive step, aided by the Alliance’s persistent advocacy efforts, in creating a stronger environment for providers and improving patient access to care. While the Alliance recognizes CMS’s efforts to reflect the costs of delivering home healthcare and the value it offers patients and the broader healthcare system in the rate setting process, the Alliance is disappointed by a continued -3% temporary rate adjustment for 2027.
“While we acknowledge a step toward a stronger operating environment with this year’s payment update, more must be done to ensure that all Americans are able to receive high-quality healthcare at home,” said Jennifer Sheets, CEO of the Alliance. “Care at home is the preferred choice for patients and families, and it delivers proven value to Medicare. Yet, the 3% temporary adjustment does not reflect the true cost of care and relies on flawed data tainted by bad actors. This impact may be compounded by provider enrollment provisions that fail to distinguish bad actors from providers operating in good faith. Taken together, there are still real risks to patient access to care that we continue to work to resolve.”
Home health leaders have repeatedly warned that rates set for 2027 still fail to align with the true cost of providing comprehensive, high-quality care. Continued payment rate constraints year after year are adversely affecting providers, including their ability to attract and retain the skilled, robust workforce needed to meet patient needs and ensure sufficient access to high-quality care at home. This is particularly true in rural and underserved communities, where there is already an access to care crisis.
The Alliance appreciates that CMS responded to stakeholder concerns by withdrawing or narrowing several enrollment proposals that could have harmed patient access. However, several provisions in the final rule remain concerning, failing to distinguish bad actors from legitimate home health and hospice providers operating in good faith. Broad-brush enrollment and disclosure provisions risk denying or revoking legitimate providers based on unrelated third-party conduct, a shared building, vendor relationships, or administrative errors. CMS now treats clinical leadership titles as presumptively reportable managing employees, and a missed or late disclosure can support a revocation retroactive to the reporting deadline. Hospices face new denial authority tied to medical director and administrator arrangements and new survey requirements to reactivate.
The Alliance has been clear that these provisions will impose additional administrative burdens on providers, diverting already limited resources away from patient care. A large coalition of providers, suppliers, and beneficiary advocacy organizations previously warned against these provisions, citing consequences for legitimate providers serving their communities. Although CMS declined to delay enforcement, the Alliance urges the agency to issue clear guidance and exercise enforcement discretion before taking action on disclosures made in good faith under the prior understanding of the rule.
The Alliance welcomes CMS’s clarification that palliative care can be furnished under the Medicare home health benefit, and its commitment to updated manual guidance and contractor instructions. We look forward to working with CMS so that guidance and quality measures reflect the needs of seriously-ill patients and their families.
The Alliance is committed to working closely with CMS and the Administration to advance the sustainable delivery of high-quality home health care, which relies on accurate, reliable data to inform payment adjustments and protect the integrity of the Medicare home health benefit. The Alliance will also continue to advocate for program integrity reforms that stop bad actors and protect beneficiaries without jeopardizing the ability of legitimate, compliant providers to deliver high-quality care.
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About the National Alliance for Care at Home
The National Alliance for Care at Home (the Alliance) is the leading authority in advancing care in the home. We envision an America where everyone has access to the highest quality, person-centered healthcare wherever they call home. Through advocacy, education, and convening, we connect providers and stakeholders to strengthen care delivery across the home-based care continuum — spanning home care, home health, hospice, palliative care, and Medicaid home and community-based services. Learn more at www.AllianceForCareAtHome.org.
Press Contact
communications@allianceforcareathome.org
Hannah Kristan | 202-355-1647