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by Kristin Rowan, Editor
The Alliance to Care at Home:
CMS needs your comments
CMS needs your comments on the home health proposed rule for FY 2026. Advocacy is a cornerstone of the mission of The National Alliance for Care at Home. From The Hill to the home, The Alliance fights for the future of the industry. But, they can’t do it alone.
Proposed Rule
The CMS proposed rule for FY 2026 has a net 6.4% decrease in payments to home health providers. Industry experts warn that this change will cause home health agencies to shutter their doors and it will leave many rural areas in a home health desert.
The Alliance Call to Action
At last week’s 2025 Financial Summit in Chicago, policy and industry experts provided ways to adjust how to write comments to CMS. According to Mary Carr, Vice President for Regulatory Affairs at National Alliance for Care at Home, it’s not enough for a few agencies and organizations to advocate for home health. Everyone has to submit comments about this. Carr says if done effectively, sending comments on proposed rules is one of the most powerful ways to stop these policy changes. The way you write your comment letters is important if you want them to have an impact.
Carr provided this guidance and tips on how to right an effective comment to CMS:
Remember that CMS is not looking for an agree/disagree statement
Provide good reasons for not keeping the proposed rule as is
Address very specific reasons why any part of the proposed rule is bad
Include the direct impact the proposal will have on your business, your staff, and your patients
Provide an alternative recommendation
Mention studies on how much less home health costs compared with SNFs and ALFs
Don’t let fear, anger, and anxiety detract from your message
Maintain professionalism and respect
Mention and thank CMS for any good aspects of the proposed rule
Include impact statements on reduction in services, delays to getting care, and areas that would be without any available home health care should the proposed rule stand
Mention the Other Side
No matter what side of the aisle you are usually on, we all must agree that care at home is an industry issue, not a Democrat or Republican issue. Hillary Loeffler, Vice President of policy and regulatory affairs at the Alliance, reluctantly mentions that the clawbacks, reductions, and methodology used to determine rates were put in place by the previous administration.
“It’s a new administration. I hate to say it, but I’m going to say, ‘This methodology was created by the Biden administration, and the Trump administration needs to do something about this.’ So, hopefully they take a fresh look at it.”
Loeffler also suggests going directly to Congress with comments and letters in addition to CMS. The recent trend of lowering reimbursement rates causing fewer visits, less coverage, and longer wait times is untenable and complete reform of the home health benefit at the federal level is needed to ensure its survival, added Loeffler.
Illogical Arguments
Whether you are publishing comments on the home health proposed rule or writing a letter to your senators and representatives, steer clear of logical fallacies. These errors in reasoning are easy to fall prey to when you have an emotional investment in the issue at hand.
Ad Hominem
The very common Ad Hominem fallicy happens when the argument moves from the problem to the person. Blaming your representative or accusing CMS of hating home health rather than focusing on the impact of the pay cut will weaken our standing.
Slippery Slope
This fallicy involves stretching the consequences of an action beyond reality. Cutting home health payment rates will decrease care and increase start-of-care delays. It will not cause homelessness, mass hysteria, or a small pox outbreak.
Fallacy of Composition
If you’re familiar with standard contracts, you’ve read the clause that goes something like, “if any part of this contract is illegal, the rest is still intact.” The composition fallacy assumes that the whole of something matches its parts. The CMS proposed rule for FY 2026 has improvements, such as allowing physicians to do face-to-face appointments even if they are not the certifying physician. Don’t throw out the entire proposed rule. Rather focus on those parts that are clearly devastating to the industry.
Fallacy of Origin
Criticizing the rule based on its authors (CMS) as adversaries to care at home also negates the impact of our advocacy. CMS has been charged with maintaining government payments for health care in hospitals, physician groups, hospices, SNFs, and more. They have also been directed to cut costs, decrease spending, and maintain budget neutrality. The proposed rule is a death sentence for home health not because it came from CMS, but because of the flawed math. Address the calculations, the methodology, the assumption that care at home is more expensive than hospital or SNF care, and the number of people who will lose access to quality care.
CMS needs your comments now
Now that you know what issues to address and how to frame your argument, reach out. Contact CMS and your Congresspeople and submit your comments today. Comments are due by August 29th.
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Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news, and speaker on Artificial Intelligence and Lone Worker Safety and state and national conferences.
She also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com
©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com
