AHPA submitted comments on the Calendar Year 2026 Home Health Prospective Payment System proposed rule.

Click here for the full comment letter. Below are some key takeaways.

• Reconsider the size and timing of the proposed home health payment reductions:
  AHPA opposes CMS’s proposed 6.4 percent aggregate reduction in Medicare home health payments, citing rising labor costs, inflation, existing agency losses, and four consecutive years of payment decreases. It recommends that CMS moderate the reductions and phase in the temporary and behavioral adjustments rather than imposing their full effects at once.
• Use a more comprehensive methodology to evaluate home health agencies’ financial health:
  AHPA cautions against relying heavily on Medicare fee-for-service margin data because Medicare represents only about one-third of its members’ home health volume. It urges CMS to account for the broader payer environment, particularly Medicare Advantage plans that reimburse substantially below traditional Medicare rates.
• Evaluate how payment reductions will affect access in rural and underserved communities:
  AHPA recommends that CMS conduct a comprehensive access-impact analysis before finalizing the reductions, with particular attention to smaller, rural, and underserved markets. It warns that the proposed payment methodology could accelerate agency consolidation, eliminate home health services in certain areas, and force more patients into higher-cost institutional settings.
• Address systemic Medicare Advantage underpayment for home health services:
  AHPA urges CMS, MedPAC, and Congress to address the disparity between traditional Medicare and Medicare Advantage reimbursement. According to AHPA, its members’ Medicare Advantage payments average nearly $90 less per home health visit, contributing to operating losses and threatening the long-term sustainability of home-based care.
• Support targeted improvements that reduce burdens and modernize home health care:
  AHPA supports expanding the types of clinicians permitted to perform the required face-to-face encounter, redesigning the Home Health Consumer Assessment of Healthcare Providers and Systems survey to reduce patient burden, and removing outdated quality measures that offer limited actionable value. However, AHPA emphasizes that agencies need sustainable reimbursement to implement these improvements successfully.