California Hospice Fraud

CMS

by Kristin Rowan | Apr 10, 2026 | CMS, Home Health, Hospice, Waste Fraud and Abuse

by Kristin Rowan, Editor

California Hospice Fraud

Multiple Arrests and Charges

Hospice fraud has been under investigation with much scrutiny by CMS. National efforts against waste, fraud, and abuse have focused on states with high probability of defrauding the Medicare Trust Fund. On April 9, 2026, California Attorney General Rob Bonta announced charges filed against 21 suspects accused of defrauding the government of $267 million. Five people were arrested and two handguns and more than $750,000 in cash were seized.

Intent to Defraud

After a credible report of fraud, an investigation ensued. The investigation uncovered this scheme. Individuals bought personal identifying information (PII) from people not living in California. They bought the PII through the dark web. They then enrolled these “people” in Medi-Cal, the California Medicaid program. Straw owners purchased 14 hospice companies and started billing Medi-Cal for hospice services for the stolen identities without providing those services.

Location Search

As part of a separate hospice fraud investigation, agencies conducted compliance reviews at a single location in Van Nuys. The address is home to more than 125 individual businesses. Of those, only 19 are licensed by the state and eligible to bill Medi-Cal. 60 percent of the remaining 109 businesses applied for hospice licenses and were denied by the state based on the moratorium on new hospices in place in California since 2021.

The 71 Million Dollar Doctor

Dr. Rajiv Bhuva has connections to Medicare claims from 126 different hospices in California, 115 of which are in LA County. The claims are for almost 2,800 patients. The average doctor cares for 140 patients annually. Dr. Oz confirmed that CMS has revoked Dr. Bhuva’s ability to bill Medicare. Dr. Bhuva has not yet been charged with a crime. A similar case in 2024 resulted in the conviction of Dr. Domingo Barrientos on the charge of conspiracy to commit healthcare fraud. Dr. Barrientos is in federal prison.

Task Force Suspends Providers

A federal anti-fraud task force working in California is investigating both hospice and home health providers. The focus is currently on Los Angeles and LA County, where high numbers of new agencies raised suspicion. As efforts have ramped up, the task force reported suspending 70 providers last week and a staggering 221 total providers suspended so far. The task force anticipates dramatically higher numbers before they’re done. The operation has identified multiple defendants and hundreds of millions in fraudulent claims.

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Kristin also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. She works with care at home software providers to create dynamic content that increases conversions for direct e-mail, social media, and websites. Connect with Kristin directly at kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2026 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

Accountability and Sustainability in Medicare Advantage

CMS

by Kristin Rowan | Apr 10, 2026 | CMS, Medicare Advantage, Regulatory

by Kristin Rowan, Editor

Accountability and Sustainability

CMS Finalizes 2027 Medicare Advantage and Part D Changes

As part of its ongoing efforts to reduce unneccessary payments, CMS issued the 2027 Medicare Advantage (MA) and Part D announcement to “improve payment accuracy” in both programs. The changes aim to make MA sustainable, allow beneficiaries to choose the best health coverage for their needs with maximum value, and make Medicare coverage more affordable.

“CMS’ vision for Medicare Advantage and Part D is clear: a great choice for seniors and a smart deal for taxpayers. The Rate Announcement improves payment accuracy and strengthens competition based on quality—not on coding practices—helping put the program on a more sustainable path for the long term.”

Chris Klomp

Director of Medicare and Chief Counselor, U.S. Department of Health and Human Services

Rate Changes for MA Risk Adjustment Model

The Rate Announcement policy changes address coding differences between MA and traditional Medicare. MA is moving toward a risk adjustment system guided by:

Reducing administrative burdens for plans and providers
Equalizing competition for all MA plans regardless of size or resources
Achieving payments that accurately reflect health risk
Facilitating the efficient use of healthcare resources, enhanced program integrity, and greater accountability

CMS will continue using the 2024 risk adjustment model in pursuit of these changes. However, CMS will exclude diagnosis information from unlinked chart review records from risk score calculation. There is an exception from the exclusion for beneficiaries who switch MA providers. The exclusion does not apply to PACE organizations, which will continue to use a blend of the 2017 and 2024 risk adjustment models. CMS expects this change to lower payments to MA plans by more than $7 billion in 2027.

Part D Risk Adjustment Model

Deductible

Part D beneficiaries cover 100% of the costs of their prescriptions, except insulin and recommended vaccines, until the deductible is met. The 2027 deductible will increase from $615 to $700.

Out-of-pocket maximum

After sunsetting the coverage gap phase in 2025, beneficiaries no long have an initial coverage limit. The initial coverage phase lasts until the annual out-of-pocket (OOP) maximum is reached. CMS is also using the API indexing method to establish the annual OOP threshold. The annual OOP will increase from $2,100 to $2,400 in 2027.

Calculation method

CMS can use one of two methods to update the annual deductible amount. The annual percentage increase (API) measures the average plan expenses per beneficiary. The Consumer Price Index (CPI) measures the annual percentage increase of all items across the U.S.

The 2026 API is 9.37%. The 2026 CPI is 2.31% CMS chose to use the API indexing method to set the 2027 deductible.

Accountability and Sustainability API and CPI 2027 Medicare Advantage Part D

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WISeR Model Not so Wise

Artificial Intelligence

by Kristin Rowan | Apr 3, 2026 | Artificial Intelligence, CMS, Medicare, Medicare Advantage

by Kristin Rowan, Editor

WISeR Model

Dangerous and Troubling

WISeR model is not as wise as CMS had hoped. For many months, we have been reporting on the waste, fraud, and abuse initiatives from HHS and CMS. From stricter oversight to fewer new agencies to broad investigations, the crackdown on wasteful spending of the Medicare Trust Fund has increased steadily. One initiative, the Wasteful and Inappropriate Service Reduction (WISeR) model, launched in Arizona, Ohio, Oklahome, Texas, New Jersey, and Washington. As the name implies, the model aimed at reducing unnecessary services by using an AI powered prior authorization algorith.

Sounds like Medicare Advantage

The WISeR model includes a limited number of procedures that require prior authorization. Even before the model launched, some were concerned that the preauthorization requirement would delay or deny necessary care, much like the prior authorization requirements in Medicare Advantage plans. The Center for Medicare Advocacy testified in opposition to the WISeR model. The spokesperson for CMA, David Lipschutz, supported three bills discussed during that hearing, including one that would stop the WISeR model altogether and prohibit using or testing any payment models for prior authorization in traditional Medicare.

Foresight was 20/20

Three months before the WISeR model launched, CMS founder Judy Stein said the program would create barriers between physician orders and approved procedures. She cautioned:

“Adding prior authorization requirements to traditional Medicare will create costly problems and barriers to necessary care. Instead, to truly address waste and abuse in Medicare, CMS should look to the dramatic overpayments and unreasonable denials in Medicare Advantage.”

Judy Stein

Founder & Senior Advisor, Center for Medicare Advocacy

Early Reports

Physician struggles

Just three months into the WISeR model demonstration, early reports from providers and patients are discouraging. The Washington Post analysis of the model didn’t include a lot of positive feedback. Physicians report challenges with the approval process. Patients wait in pain until needed care is approved. Issues with the technology include problems with online portals as well as struggles with coordination and communication with tech firms and claims processors. Physicians also report denials for care that is within coverages guidelines and decisions that take longer than federal guidelines allow.

Unintended consequences

Part of the model intended to reduce unnecessary spending is a built-in incentive program for cost savings. The tech companies handling the AI algorithms are paid partly on the savings realized after denying medical services. This creates an inherent goal of adjusting the algorithm to deny more services, even if those services are necessary. The model supposedly balances this with pay adjustments for quality measures that include accuracy in decision-making. These tech companies are not staffed by medical professionals and it is unclear what they use as the basis for their decision-making algorithm.

Exemptions

Officials from Medicare say they intend to offer exemptions to physicians with a high authorization rate. These physicians would no longer be subject to the AI prior authorization if, over time, most of their submitted services are authorized. Taking this to its logical conclusion:

Physicians may dial back on recommended procedures until they get the exemption
Once exempt, physicians can circle back and get the procedures for their patients without prior approval
Tech companies may increase denials to ensure continued work
AI oversight of federal health spending could increase if the pilot program saves money, regardless of patient outcomes

Writing was on the Wall

Long before the WISeR model existed, AI algorithms for care authorizations had denied needed care. Insurance companies started using AI to process prior authorizations in 2020. Both UnitedHealth Group and Humana used nH Predict AI for care authorizations for Medicare Advantage. The family of an elderly couple sued UnitedHealth after their care was denied and the couple died. A class action suit against Humana claimed nH Predict AI Model predictions are highly inaccurate and are not based on patients’ medical needs. In February of 2024, CMS clarified the use of AI cautioning that “compliance is required with all of the rules at § 422.101(c) for making a determination of medical necessity, including that the MA organization base the decision on the individual patient’s circumstances.”

Unclear Future

After only a few months, officials have not indicated whether the WISeR model could expand into additional states or to cover additional procedures in the future. Beneficiaries say they stayed with the traditional Medicare plans specifically to avoid the prior authorization hurdles inherent in Medicare Advantage plans. CMS may have additional information by July, when the program has more data.

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Hospice CARE Act

Hospice

by Kristin Rowan | Apr 3, 2026 | Hospice, Medicare, Regulatory

by Kristin Rowan, Editor

Hospice CARE Act

Congress breathes new life into hospice protection

In 2024, Representative Blumenauer (D-OR) introduced the Hospice Care Accountability, Reform, and Enforcement Act. The Bill, H.R. 9803, aimed “to amend title XVIII of the Social Security Act to ensure the integrity of hospice care furnished under the Medicare program.” The House referred the act to the Committee on Ways and Means and the Committee on Energy and Commerce for consideration. The Committee on Ways and Means later referred the act to the Subcommittee on Health, where it apparently remains under consideration.

On March 18, 2026, Congresswoman Sanchez (D-CA) and Senator Warner (D-VA) introduced, or re-introduced, the Hospice Care Accountability, Reform, and Enforcement (Hospice Care) Act. According to the joint press release from its sponsors, the act will “modernize the Medicare hospice benefit, protect patients and taxpayers from fraud, and expand access to essential services and caregiver support.”

Program Integrity and Payment Reform

The two primary foci of the act are program integrity provisions and payment reforms. The hospice benefit remains largely unchanged since it began in 1982 despite significant changes in both the providers delivering and patients receiving end-of-life care. The rise in reports of fraud and abuse puts into question whether the current system can ensure both meeting the needs of patients and families and safeguard the Medicare Trust Fund.

“Hospice should provide comfort and dignity at the end of life, yet the benefit has not evolved to meet families where there is need. This bill strengthens and enhances Medicare’s hospice benefit so it provides the critical care patients and their families need – like respite care for caregivers and coverage of palliative treatments like dialysis and radiation – all while protecting the program from those trying to exploit it.”

Linda T. Sanchez

Congresswoman, D-CA

Program Integrity

According to the sponsors, the bill “creates additional safeguards to precent fraudulent providers from enrolling in Medicare and increases oversight of hospices, especially new hospices.”

Specifically, the bill:

Temporarily prevents new hospices from enrolling in Medicare, while allowing exceptions for instances where additional access to care is needed.
Requires increased transparency of hospice ownership and managing control information, ensuring CMS’s enrollment records are up to date.
Increases survey frequency for new hospices to ensure they meet hospice health and safety standards and prohibits payments to hospices that do not submit required quality data to the Secretary, with appropriate exceptions.
Reduces the potential for inappropriate financial conflicts of interest when certifying individuals’ eligibility for hospice care, while allowing nurse practitioners and physician assistants to also certify eligibility.
Requires CMS to conduct additional oversight activities to ensure hospices are providing holistic and comprehensive care.
Provides patients with an explanation of benefits within 15 days of an individual’s hospice election to increase beneficiary awareness of hospice enrollment and prevent extended periods of fraudulent billing.

Payment Reform

The bill “ensures that providers are incentivized to deliver high-quality care to individuals and their families.”

Specifically, it:

Revises the payment structure for routine home care to reward hospices for providing in-person care.
Increases payments to hospices for furnishing palliative radiation, chemotherapy, blood transfusions, and dialysis to address access barriers for individuals that require these costly treatments under a hospice election. Additionally, it creates an outlier payment policy to provide a backstop for providers delivering care to high-cost patients.
Adds home respite care to the Medicare hospice benefit, allowing individuals to receive respite care at home rather than in a facility, which is a key benefit for families and caregivers that are taking care of loved ones at the end-of-life.
Creates a new transitional inpatient respite benefit to support patients and families through their transition from a hospital into hospice care in the setting of their choice, allowing patients to move from hospital to general inpatient care to transitional respite, when appropriate. This new transitional payment seeks to eliminate the current pattern of care whereby terminally ill individuals are discharged from the hospital and inappropriately admitted to a skilled nursing facility in lieu of electing hospice care.

“Making decisions about hospice and end-of-life care is one of the most difficult moments that families can endure, yet Medicare’s hospice benefit is out-of-touch with the needs of patients and providers. I’m proud to introduce this legislation that will prioritize patient comfort at home as well as in a health care facility, and protect patients and taxpayers from bad actors attempting to steal essential resources.”

Mark Warner

Senator, D-VA

Industry Support

The Hospice CARE Act received wide-spread industry support after its introduction to Congress.

American Academy of Hospice and Palliative Medicine

“Patients and families in need of the care, comfort and quality of life that hospice care provides need to trust that they are receiving the best possible services. We look forward to working with Representative Sánchez and Senator Warner on these important issues and to ensure that all patients have access to this vital care.”

– Kristina Newport, CMO for AAHPM

Center for Medicare Advocacy

“In addition to significant payment reforms and program integrity measures, this bill takes important steps towards improving access to care for individuals on hospice.”

-David Lipschutz, Co-Director for the Center for Medicare Advocacy

National Alliance for Care at Home

“Hospice care is one of the most profound services our healthcare system offers, providing patients and families with compassionate, dignified care during life’s most difficult moments. As the number of Americans turning to hospice continues to grow, it is critical that the benefit keeps pace with how care is delivered today and what patients, families, and providers actually need. The Alliance looks forward to working with Representative Sánchez and Senator Warner and their congressional colleagues on this legislation. We are committed to being a constructive partner in any effort to protect what’s working, address what isn’t, and modernize the Medicare hospice benefit in ways that serve patients, families, and the future of care in our country.”

-Jennifer Sheets, CEO for The Alliance

LeadingAge

“At its best, compassionate, high-quality, person-centered care is delivered to beneficiaries and families by ethical, forward-thinking, competent providers, in keeping with the sector’s nonprofit origins, which established a standard of quality care. Currently, however, hospice is at an inflection point. Increased scrutiny – an appropriate response to fraudulent behavior of a limited group of bad actors – highlights the need for modernization.

-Katie Smith Sloan, President and CEO for LeadingAge

National Partnership for Healthcare and Hospice Innovation

“This legislation provides an important opportunity to pursue thoughtful reforms to the Medicare hospice benefit that both preserve patient access and address ongoing concerns related to program integrity. While the bill represents meaningful progress toward modernizing the benefit and reducing incentives for fraud, waste, and abuse, NPHI believes certain provisions – particularly those related to payment reform – present opportunities for further discussion and refinement.”

– Tom Koutsoumpas, Founder and CEO of NPHI

More Information

A section-by-section analysis of the bill is available HERE
A one-pager of the bill is available HERE

Congress is on recess until the middle of April. The last few months will dictate the priorities when the next session starts, which will likely be focused on finalizing the budget and fully reopening the government. Whether the Hospice CARE Act will progress past its 2024 version is unclear. The Rowan Report will continue to monitor its progress.

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Kristin Rowan is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news. She is also a sought-after speaker on Artificial Intelligence, Technology Adoption and Lone Worker Safety. She is available to speak at state and national conferences as well as software user-group meetings.

Kristin also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. She works with care at home software providers to create dynamic content that increases conversions for direct e-mail, social media, and websites. Connect with Kristin directly at kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2026 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

MedPAC Finalizes Recommendation to CMS

Advocacy
by Kristin Rowan | Jan 30, 2026 | Advocacy, CMS, Home Health, Hospice, Medicare, Regulatory

by Kristin Rowan, Editor

MedPAC Recommends 7% Cut

Vote Finalized

In December, MedPAC published a proposed recommendation for calendar year 2027 that included a 7% cut to home health reimbursement rates and no increase for hospice. Last week, MedPAC voted to finalize that recommendation and send it to CMS.

Industry Objection

Both the proposal and final recommendation met with strong industry backlash.

“MedPAC’s dangerous and misguided recommendations to reduce the Medicare home health base payment rate by 7% for CY 2027 and eliminate the update to the 2026 Medicare base payment rate for hospice do not reflect both home health and hospice agencies’ operating realities as well as the cumulative impact of recent policy changes. For home health agencies, any cut – let alone one of such great magnitude – will threaten the ability to meet individuals’ healthcare needs. Yet again, the Commission is failing to understand the operating reality providers face and the potential patient harm that any further payment cuts pose.”
Dr. Steve Landers
CEO, National Alliance for Care at Home

Consistently Wrong

The MedPAC recommendation may not be built on solid data, use accurate calculations, consider Medicare Advantage and Medicaid rates along with Traditional Medicare FFS, consider the number of agencies that will go out of business, have any recommendations for maintaining nurse and caregiver hourly rates, or fairly distribute Medicare funds across disciplines, but, wait…where was I going with this? Oh, right! At least they’re consistent. MedPAC recommended a 7% decrease in Medicare payments for 2027, 2026, 2025, 2024, and 2023. They may be completely wrong, but they are dedicated to maintaining their wrongness.

Final Thoughts

Despite the years of 7% cut recommendations from MedPAC, the final numbers from CMS are rarely in line with those recommendations. We will, of course, know more when CMS publishes their proposal later this year. LeadingAge, National Association for Care at Home, individual and corporate HHAs and Hospices, and anyone else with a stake in the care at home industry, should contact their congressional representatives and CMS directly to voice concerns over these cuts.

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Kristin Rowan is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news. She is also a sought-after speaker on Artificial Intelligence, Technology Adoption and Lone Worker Safety. She is available to speak at state and national conferences as well as software user-group meetings.

Kristin also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. She works with care at home software providers to create dynamic content that increases conversions for direct e-mail, social media, and websites. Connect with Kristin directly at kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2026 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

UnitedHealth Group Publicity Stunt

CMS
by Kristin Rowan | Jan 30, 2026 | CMS, Editorial, Medicaid, Medicare, Medicare Advantage, Regulatory

by Kristin Rowan, Editor

UnitedHealth Group Publicity Stunt

How to Distract the Public: 101

When customers and regulatory bodies start to complain about company practices, reputation management usually gets involved. An internal or external public relations, crisis communication, and/or reputation management specialist advises the company on how to overcome negative press.

Transparency & Action

When Dominos Pizza employees recorded a disturbing “hoax” video, the CEO went to the same medium (YouTube) to address the video, apologize, and reassure customers. This issue was handled so well that it is used as a teaching tool in PR classes.

In 1982, when a couple tampered with bottles of Tylenol in Chicago and seven people died, parent company Johnson & Johnson stopped advertising, recalled 31 million bottles across the country, switched to tamper-proof packaging, and personally communicated with 450,000 retailers.

Subterfuge, Smoke & Mirrors

Last week, when UnitedHealth Group, already under investigation for bribing nurses, wrongful death, and Medicare Advantage billing fraud, was called to testify before House committees about their record-high premiums, rising claims denials, and unneccessary waiting over prior approvals, UHG CEO prepared a written statement to read to the Energy & Commmerce Committee that included blaming hospital costs, pricing differences, frequency of testing, drug prices, and pharmaceutical advertising for higher premium rates; extolling the virtues of Medicare Advantage over Traditional Medicare, using incorrect and misleading information; and casually mentioning that they will “voluntarily eliminate and rebate our profits” for their ACA customers.

Gesture too Small to be Meaningful

The months long Congressional stand-off on healthcare premium subsidies continues. Affordable Care Act participants saw healthcare premiums jump over night when the subsidies expired. (Mine went up 400%).

In 2025, UnitedHealth recorded $12.1 billion in profit. But, that profit is spread out over nearly 3,000 wholly owned subsidiaries who take almost 30% of what UHG pays out in care costs. The company has increased its Medical Loss Ratio to 87% by hiring their own subsidiaries to engage in “quality improvement,” virtually eliminating ACA profit.

Of its 50 million subscribers, only about 1 million are ACA customers. Even if the company returns the ACA profits, it will return 1/50th of its profits and keep the rest. In their third quarter earnings call, UHG said it expected 2026 enrollment to be 1/3 of that in 2025. The 2026 outlook estimates an overall increase in profit to more than $14 billion, most of which will never find its way back to ACA participants.

The Truth Behind the Curtain

On January 27, 2026, just one week after the profit-sharing announcement, UnitedHealth Goup addressed shareholders in its Q4 and 2025 Earnings Call. During that call, newly appointed UnitedHealthcare CEO Tim Noel said:

“Nearly all of our employer Group and fully insured pricing align with continued increases in care activity for 2026. In the Individual ACA market, we repriced nearly all states in response to higher medical trends and the elevated needs of ACA beneficiaries in 2025…. These actions should expand operating earnings margins for UnitedHealthcare by 40 basis points, and are expected to result in membership contraction of 2.3 to 2.8 million.”
Tim Noel
CEO, UnitedHealthcare

Other statements during the call reinforced the company’s drive toward profit.

They are focusing attention in markets where they have “complimentary wrap-around services” already in place. Which means they have owned subsidiaries to shift money to instead of lowering premium rates. Additionally, they have “narrowed [their] affiliated network…with the goal of having a more optimal alignment of physicians….”

New Speak

Throughout the earnings call, company spokespeople used terms like repositioned, streamlined, aligned, membership contraction, and repriced. They carefully avoided saying that they dropped physician services outside those they owned, removed plans that paid out too much, consolidated businesses to increase profits, lost millions of members due to price increases and other plan problems, and raised prices across the board, even on plans that were already profitable.

Final Thoughts

UHG CEO Hemsley made a few statements to Congress I agree with. Drug prices are too high. Hospital and Ambulance prices are too high. Pharmaceutical companies advertise too much and use the cost to offset tax liability.

There were also some statements Hemsley almost got right.

He said small businesses should be allowed to join AHPs with fewer restrictions. There should be no restrictions on industry or geography.

He said HSA thresholds should be lowered for HDHPs. HSAs should be available to everyone, regardless of plan, deductible, payer, or whether they are on a group, individual, or ACA plan.

Hemsley thinks broker compensation should be standardized in the ACA market. If payers want broker compensation, standardized or not, ACA or Medicare Advantage, the compensation should come from the payer and not be included in premiums.

He wants consumers to have expanded access to catastrophic plans and to allow the use of premium tax credits. All plans and payers should be available to everyone, everywhere. Increasing competition in plans and players will drive down costs.

I applaud Congress for bringing the large payers in to discuss exhorbitant premium rates, but I’m still waiting on them to take action based on the information they received.

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Kristin Rowan is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news. She is also a sought-after speaker on Artificial Intelligence, Technology Adoption and Lone Worker Safety. She is available to speak at state and national conferences as well as software user-group meetings.

Kristin also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. She works with care at home software providers to create dynamic content that increases conversions for direct e-mail, social media, and websites. Connect with Kristin directly at kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2026 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

VA Updates Community Cares Contracts

Admin
by Kristin Rowan | Jan 23, 2026 | Admin, CMS, Regulatory

by Kristin Rowan, Editor

VA Issues RFP

Updates to Community Care Contracts

Some Veterans receive care from VA providers. Non-VA providers can still provide care for Veterans through a Community Care contract with the U.S. Department of Veterans Affairs (VA). In late 2025, the VA released a Request for Proposal (RFP) for new CC contracts. The new contracts are designed to substantively change non-VA provider care to Veterans.

According to the VA, the new contracts are intended to:

Increase choice through an IDIQ model that allows multiple health plans to compete to serve Veterans

Raise quality of care by requiring plans to follow broad standards of care adopted by major health systems

Improve oversight and quality of care using better data, technology, and real-time management

Add flexibility so the VA can issue competitive task orders and remove underperforming contractors

How Does This Impact Care at Home?

The primary contractor, and therefore the ones responsible for bidding and ensuring quality of care are the health plans. So, how does this change impact home care and home health providers? Here’s how:

Fast changes in network participation along with sudden shifts will inevitably come as a result of plans competing and task orders changing

Plans will need to align with VA targets, so expect waves of onboarding, recurring pushes for credentialing, and increased local networking

Because the plans will be held to quality standards, you can expect that those standards will flow through provider documentation, timeliness, claims accuracy, and EVV and FWA compliance

IDIQ is specifically designed to allow changes in the middle of care, which means the VA and health plans can add or change rules or portal, and make revisions to edit sets during the contract

Get Ahead of the Changes

Plan to make some changes before these new Community Care contracts come to your local health plans. In order to comply with the contract requirements, your credentialing packets need to be updated to include up-to-date CAQH, insurance, licenses, and compliance. This will help minimize the lag-time before getting paid.

Anticipate Expectations

The health plans will be competing for contracts, so they will expect you to compete as well. Awarded contracts will likely be fulfilled by agencies who have a high clean claim rate and quick response to edits and denials. Whatever you are using for coding, documentation, and rules need to be validated before the new care contracts start. Complete documentation will comply with the VAs focus on better data and real-time management. Make sure your team is executing precise reports; centralize your records, documentation, and audits to prove performance records and decrease issue resolution time.

Final Thoughts

Non-VA providers who want to be considered to provide care to Veterans need to show alignment with the VA’s goals to expand choice, raise quality, and increase oversight. Planning ahead by meeting those standards early will make the transition process smoother one the new contracts roll out. We will continue to provide resources and information on these Community Care contracts as they are available.

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Kristin Rowan is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news. She is also a sought-after speaker on Artificial Intelligence, Technology Adoption and Lone Worker Safety. She is available to speak at state and national conferences as well as software user-group meetings.

Kristin also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. She works with care at home software providers to create dynamic content that increases conversions for direct e-mail, social media, and websites. Connect with Kristin directly at kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2026 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

LeadingAge and Alliance Join Dr. Oz

CMS
by Kristin Rowan | Jan 15, 2026 | CMS, Medicaid, Medicare, Medicare Advantage, Regulatory

LeadingAge and Alliance Join Dr. Oz

CMS hosts listening session in LA

On January 9, 2026, CMS Administrator Dr. Mehmet Oz hosted a listening session in Los Angeles to discuss fraud, waste, and abuse in home health and hospice. Dr. Oz was joined by CMS Director of the Center for Program Integrity Kim Brandt and Director of the Center for Medicare Chris Klomp.

Statement to Dr. Oz

Representatives from both LeadingAge and the National Alliance for Care at Home attended the session. As part of their ongoing collaboration and participation in combatting fraud, waste, and abuse, the two organizations sent a joint letter to Dr. Oz regarding recommendations to strengthen program integrity.

“We strongly support CMS’s ongoing efforts to strengthen program integrity and believe that fraud, waste, and abuse can be effectively prevented and addressed while reducing burden on legitimate providers furnishing critical services in the home. As CMS continues to refine its oversight strategies, we encourage the agency to adopt measures that are analytically rigorous, operationally feasible, and take a targeted risk-based approach, consistent with CMS’s statutory authorities.”
LeadingAge and the Alliance

CMS Fraud Prevention

CMS has identified areas of waste fraud and abuse they are actively working to combat. In 2025, CMS imposed nearly 500 payment suspension, stopping nearly $5 billion in payments. CMS identified $2.3 billion in overpayments and implemented automated edits to guard against improper payment. They also revoked Medicare billing from 4,780 providers and denied almost 112,000 claims for unnecessary services.

The Alliance

Members of National Alliance for Care at Home (The Alliance) attended the listening session with Dr. OZ, stating that program integrity is a key priority for the organization. The alliance continues to work closely with lawmakers and regulators to ensure providers are putting patients’ needs first without unnecessary or fraudulent claims.

“The Alliance appreciates the opportunity to continue our dialogue with CMS about ensuring program integrity across these essential home-based services. We share the administration’s goal of eliminating fraud, waste, and abuse in home health and hospice care, and will continue to partner with the agency as it pursues solutions that reduce the burden on legitimate providers and protect patient access to care at home.”
Dr. Steve Landers
President, The Alliance

LeadingAge

Members from LeadingAge also attended the listening session stating that fraud in any care setting is concerning and preventable. The organization continues to work with CMS to address fraud and strengthen regulatory safeguards.

“We thank CMS for initiating this productive meeting, and for the input from Administrator Oz, Deputy Administrator and Chief Operating Officer Kim Brandt, and Deputy Administrator and Director of Medicare Chris Klomp. We look forward to continuing collaboration on this important issue.”
Katie Smith Sloan
President and CEO, LeadingAge

Interview with LeadingAge

The Rowan Report reached out to LeadingAge for a comment on the listening session with CMS. We are scheduled to speak with Mollie Gurian, VP of Policy and Government Affairs, this afternoon. We will update this article with that information immediately following the interview.

# # #

Kristin Rowan is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news. She is also a sought-after speaker on Artificial Intelligence, Technology Adoption and Lone Worker Safety. She is available to speak at state and national conferences as well as software user-group meetings.

Kristin also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. She works with care at home software providers to create dynamic content that increases conversions for direct e-mail, social media, and websites. Connect with Kristin directly at kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2026 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

UnitedHealth Causes Heightened Alarm

Breaking News
by Kristin Rowan | Jan 9, 2026 | Breaking News, CMS, Legal, Medicare Advantage, Outcomes, Regulatory

by Kristin Rowan, Editor

UnitedHealth Causes Heightened Alarm

Guardian Investigation Launches Probe

In July of 2025, The Guardian reported that UnitedHealth had secretly paid nursing homes to reduce hospital transfers. The investigation revealed that UnitedHealth was placing its own medical teams inside nursing homes and pushing them to cut care expenses, delay transfers, and deny care.

Senators Push for Answers

In the weeks following The Guardian report, Senators Ron Wyden (D-OR) and Elizabeth Warren (D-MA) launched their own investigation of the insurance giant’s cost cutting measures in nursing homes. Wyden and Warren sent a letter to then UnitedHealth Group leaders requesting documents and information about the nursing home incentive program.

New Allegations

A new letter from Senators Wyden and Warren states that UHG has refused to comply with the initial request. In the months since the demand for information, UHG has provided only “brief and unsubstantial answers” to their questions.

“Because you have failed to respond adequately to our inquiry – and in light of additional recent reporting – we are renewing our inquiry with heightened alarm.”
Ron Wyden and Elizabeth Warren
United States Senators

Additional Reports

The Senators’s letter alludes to recent additional reports. They were referring to a December story, also from The Guardian, reporting allegations of wrongful deaths inside the nursing home care program. In a statement, UnitedHealth denied any allegations their practices “endanger patient safety or violate ethical standards.”

No Response is a Response

When asked about the second letter, UnitedHealth Group did not respond to reporters at The Guardian. UHG leadership said in statement that they would “continue to engage” with the senators. The company’s leadership also maintains that its nursing home program “improves outcomes” and “reduces unnecessary hospitalizations.”

Unanswered Questions

UnitedHealth attended a briefing with the senators’ offices last July. During that meeting, UnitedHealth made several claims the Senators are now questioning.

UHG maintained their nurses are not required to contact company representatives prior to taking a nursing home patient to the hospital, but a document provided by a whistleblower alleges the opposite

UHG failed to adequately explain why hospital admission rates are part of the metrics for determining bonuses

UHG chose not to respond to questions about pending wrongful death lawsuits for Mary Grant, Cindy Deal, and an unnamed nursing home resident in New York

Deadline to Comply

Senators Wyden and Warren allege that UnitedHealth Group has withheld internal documents that directly relate to their initial request for information. The senators gave a deadline of January 28, 2026 to respond with the following information:

Hospitalization policies, including clinical protocols for determining when transfers are warranted, definitions of avoidable versus unavoidable hospitalizations, and whether staff must consult Optum supervisors before hospital transfers.

Bonus program metrics and thresholds, including how UnitedHealth determines APK limits, whether facilities are penalized for exceeding thresholds, and five years of documentation on bonus payments to nursing homes.

Advance directive policies, including training materials for end-of-life conversations, the mortality risk assessment tool used, and who participates in those discussions with residents.

Marketing and enrollment practices for I-SNP plans at contracted nursing homes.

Federal oversight and compliance, including any CMS sanctions or enforcement actions in the past five years.

Failure to Respond

Without adding details, the letter states that should UnitedHealth Group fail to respond it full, they will seek answers to their questions using “all tools at the Committee’s disposal.”

This is an ongoing inquiry/investigation and story. The Rowan Report will continue to provide updates as they become available.

# # #

Kristin Rowan is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news. She is also a sought-after speaker on Artificial Intelligence, Technology Adoption and Lone Worker Safety. She is available to speak at state and national conferences as well as software user-group meetings.

Kristin also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. She works with care at home software providers to create dynamic content that increases conversions for direct e-mail, social media, and websites. Connect with Kristin directly at kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2026 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

LEAD Replaces REACH

CMS
by Kristin Rowan | Jan 9, 2026 | CMS, Hospice

by Kristin Rowan, Editor

LEAD Replaces REACH

CMS Launches 10-Year Model Test

LEAD replaces REACH in new 10-year CMS model. The Long-term Enhanced ACO Design (LEAD) model is scheduled to launched at the end of 2026, following the end of ACO Realizing Equity, Access, and Community Health (REACH). LEAD is a voluntary model that will run January 1, 2027 thorugh December 31, 2036, the longest CMS has ever run a test.

Key Takeaways

CMS provides the following information:

Problem: Many health care providers have not historically participated in or dropped out of ACOs because of financial and administrative obstacles to success.

Solution: LEAD is designed to address such barriers to support both established and newly created ACOs by providing them enhanced, flexible cash flow payments; and greater freedom and tools to support spending time with and meeting patient needs, including those with specialized care needs.

Outcomes: Through ACOs, health care providers will be empowered to deliver coordinated, accountable care and preventive services — keeping patients healthier and helping to reduce health care costs and unnecessary emergency room visits and hospitalizations.

Strategy: LEAD advances the Innovation Center’s commitment to 1) building opportunities for independent health care providers and practices to be rewarded for delivering better care, 2) promoting and empowering patient choice in both coverage and sites of care, and 3) making it easier for health care providers and patients to engage in preventive care that supports healthier living.

LEAD Goals

According to CMS, the LEAD Model will improve care coordination among a broad range of healthcare providers, including hospices. The model will also appeal to providers with specialized patients and those who are newer to ACOs like small, independent, or rural-based practices. The LEAD model intends to incentivize providers downstream such as home health agencies, palliative care, and hospices, to engage with the providers upstream. It is particularly aimed at complex patients with high needs.

CMS has outlined a 3-part framework for its goals:

Increase the scope of ACOs to include rural, small, and independent providers and health centers

Enhance evidence-based prevention and care coordination for more patients

Empower patient choice and encourage patient participation in care

Planning Phase

The LEAD Model will begin its planning stage in March of 2026 and run through December of 2027. During that time, CMS will identify two states to partner with for developing the framework for Medicaid partnerships. The framework will include how ACOs and Medicaid organizations can share data and coordinate care.

CARA

Among the more prominent changes in the LEAD Model is the CMS Administered Risk Arrangements (CARA). CMS will assist LEAD ACOs in designing episode-based risk payment arrangments with other health care providers. According to CMS, CARA will facilitate stronger preferred provider relationships. Building these strong care networks and partnerships between ACOs and hospice and palliative care providers will improve care for high-needs patients.

Hospice and palliative care organizations will need to demonstrate partnership value to ACO organizations by supporting smooth care transitions, reducing unnecessary hospitalizations, and ensuring patients receive the right care at the right time, according to a statement from The Alliance.

Final Thoughts

This new model may provide some opportunities for hospice agencies. It may also pave the way for a reimbursement model for palliative care. Although the statements from CMS focus on hospice and palliative care, there may be opportunities for home health agencies as well. These opportunities may become more apparent once the model demonstration begins in 2027. If they are not immediately apparent, we have 10 years to figure them out.

Applications for participation will open in March. To stay connected and receive updates from CMS, join the LEAD Model List or contact the LEAD Model team.

# # #

Kristin Rowan is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news. She is also a sought-after speaker on Artificial Intelligence, Technology Adoption and Lone Worker Safety. She is available to speak at state and national conferences as well as software user-group meetings.

Kristin also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. She works with care at home software providers to create dynamic content that increases conversions for direct e-mail, social media, and websites. Connect with Kristin directly at kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2026 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

Subsidies Undecided

Medicaid
by Kristin Rowan | Dec 12, 2025 | Medicaid, Medicare, Regulatory

by Kristin Rowan, Editor

Subsidies Undecided

Senate cannot agree

The record-breaking government shutdown centered around one issue: extending the COVID-era Affordable Care Act supplemental subsidies. The subsidies were an additional discount for Americans within a certain income bracket. They helped make healthcare insurance through the ACA marketplace more affordable during and after COVID. The subsidies have been extended multiple times and expire at the end of the year. Senate Republicans are not willing to extend them again. Senate Democrats won’t vote in favor of any health care proposal that doesn’t include them.

Time is Running Out

Not only do the subsidies expire at the end of the year, but anyone enrolling in a marketplace plan has to apply by December 15th, leaving precious few days to find a way forward. Senate Democrats proposed a straight three-year extension of the subsidies, which failed. Senate Republicans proposed using the subsidy money to contribute to HSAs for bronze or “catastrophic” plans. That proposal also failed.

A hybrid compromise is in the works. Details have not been released but it will likely include income caps and eligibility restrictions on the subsidies as well as some HSA flexibility. Without an extension on the subsidies, premiums are expected to increase an average of 26% in 2026, although some analyses suggest premiums could go up by 73-90%.

Another Shutdown?

The 43-day shutdown that ended in November did not finalize the 2026 budget. It merely passed enough appropriations to temporarily fund some departments through January 30, 2026 and a few essential departments for longer. If the Senate and House cannot agree on the subsidy issue, we face another shutdown in February. Every shutdown impacts Medicare & Medicaid payments, approvals, and renewals.

Experts indicate nearly 50% of people buying marketplace plans are ages 50-64. Most, if not all of them, are looking at lower cost (and lower benefit) plans or dropping insurance altogether in 2026. If insurance costs remain high, this group of

people will enter Medicare with poorer health, which will cost the Medicare program and tax payers more in the long run. It will cause a vicious circle of higher Medicare costs, leading to higher taxes, lower subsidies, higher premiums, fewer people being covered, and finally higher Medicare costs again.

This is an ongoing story and The Rowan Report will continue to bring you the latest news on the subsidies and the impending expiration of the temporary government funding as we head into 2026.

# # #

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

CMS Proposed Changes

Advocacy
by Kristin Rowan | Dec 12, 2025 | Advocacy, CMS, Medicaid, Medicare, Medicare Advantage, Regulatory

by Kristin Rowan, Editor

CMS is Making Changes

Good or Bad?

CMS is making changes across Medicare and Medicare Advantage. From Star Ratings to Prescription Drug Prices to the Hospice benefit, CMS is embracing Make America Healthy Again. Will these initiatives benefit Medicare and Medicare Advantage recipients or the insurance companies who provide the plans?

Drug Payment Model

In early November, CMS announced a plan to lower prescription drug costs for Medicaid recipients. State Medicaid programs can opt in to the GENErating cost Reductions fOr U.S. Medicaid Model (GENEROUS). The pilot program is using the most-favored-nation pricing that was recently negotiated and announced by President Trump. Most-favored-nation pricing requires prescription drug manufacturers to charge the same low rate paid in other countries.

Limited Pilot

Beginning in 2026, CMS will negotiate with manufacturers of select drugs for lower pricing. Participating states will start using uniform, transparent coverage criteria. This is not criteria for inital coverage in Medicaid, but for standardizing access to high-cost medications.

Manufacturers are not required to participate in the GENEROUS Model, but can voluntarily apply. Participating manufacturers agree NOT to seek additional supplemental rebates or discounts outside the model price.

New Medicare Advantage Policies

CMS has proposed updates to the Medicare Advantage and Medicare Part D programs. The new plan would begin in CY 2027 and includes major changes to the Star Ratings system. CMS is also seeking feedback on new ways to modernize MA.

Star Rating Changes

The proposed changes are supposed to incentivize plans to improve care. CMS suggests removing 12 unique measures that look at administrative processes and those that don’t highlight differences between plans. Star Rating measurements of care, outcomes, and patient experience will remain.

Request for Feedback

CMS is seeking feedback on Medicare Advantage changes, including improving competition, refining risk adjustment, and aligning quality incentives to deliver greater value. CMS is open to either a limited model test or program-wide changes. Interested parties can submit feedback through January 26, 2026. Read the Proposed Rule here. Submit your comments.

Expanding Technology-Enabled Care

CMS may finally be recognizing what we’ve been promoting for 25 years: Care improves with technology support.

The ACCESS model tests a new payment approach in original Medicare to expand access to technology-supported care options. CMS aims to increase technology-supported care options to improve health and prevent and manage chronic diseases. More than two-thirds of Medicare beneficiaries are dealing with high blood pressure, diabetes, chronic musculoskeletal pain, and depression.

An interest form is now available for the 10-year Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model test. The model test begins July 1, 2026. The application to participate must be received by April 1, 2026.

Impact

As these programs roll out between now and 2029, the impact on insurance plans, payors, beneficiaries, and taxpayers will unfold. Will lower cost prescriptions and technology-based care lower insurance rates? Payor reform may be necessary to change out-of-pocket costs. Regulations may have to further incentivize payors to increase care when costs go down, particularly with value-based care models.

Please take a few minutes to read the details on each of these proposals, add your comments, and sign up to participate. The industry needs reform and our aging family members deserve better.

# # #

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

Feedback Adjusts Final Rule

CMS
by Rowan Report | Dec 4, 2025 | CMS, Medicare, Regulatory

FOR IMMEDIATE RELEASE
November 28, 2025

Contact: Hannah Kristan
communications@allianceforcareathome.org
202-355-1647

National Alliance for Care at Home: CMS Modifies Final Payment Rule Based on Stakeholder Feedback, but 1.3% Cut Still Undermines Access

Despite positive changes in final rule, home health leaders remain deeply concerned payment cuts will continue to impact patient access to care at home

ALEXANDRIA, VA and WASHINGTON, D.C. The National Alliance for Care at Home (the Alliance) today acknowledged that the Centers for Medicare & Medicaid Services (CMS) made significant adjustments in the Home Health Perspective Payment System (HH PPS) Final Rule for CY 2026 in response to community concerns regarding patient access and data integrity.

However, the Alliance remains concerned that any payment cut for home health providers will continue to compromise access for the millions of Medicare beneficiaries who rely on these services to age and recover from illness or injury safely at home.

Since 2019, Medicare home health providers have experienced severe cuts that have already led to a cascade of home health agency closures and reduced patient access to care, especially in rural and underserved communities. The cuts finalized by CMS today – 1.023% permanent and 3% temporary – will likely continue to exacerbate these trends.

“While the Alliance acknowledges that CMS took into account some of the home health community’s recommended changes in its final rule, resulting in a lower payment cut for next year, a 1.3% overall reduction in payments compared to 2025 will likely result in continued reductions in patient access, the closure of more home health agencies, and more patients waiting in costly hospital settings instead of recovering safely at home.”

– Dr. Steve Landers, CEO for the Alliance

The Alliance commends CMS for revisiting aspects of its flawed payment approach, including the conclusion of permanent payment adjustments with CY 2026 (using data from CY 2020 through 2022) based on issues that CMS acknowledged with isolating PDGM behavior changes from non-PDGM behavior changes in CYs 2023 and beyond. In total, CMS’s changes from proposed to final rule amount to approximately $915 million more in payments to home health agencies for 2026. However, any cut will be detrimental in the face of years of compounding decreases, and more action is needed to help preserve integrity, stability, and predictability in Medicare’s home health benefit. While CMS reduced the amount of overpayments that inform the temporary payment adjustments down to 4.7 billion for CYs 2020 through 2024, home health agencies will continue to face several more years of temporary adjustments without additional action.

“Home health care is among the most trusted, cost-effective, and patient-centered services in the Medicare program. The Alliance thanks its members, the broader home health community, and allied organizations and leaders for their advocacy to help achieve this substantial improvement for home health providers and patients nationwide. Congress must take further action to enact lasting reforms to the system that protect patient access to these services and ensure the sustainability of the Medicare home health benefit.”
Steve Landers
CEO, National Alliance for Care at Home

Expanding access to home health care is essential to improving health outcomes, enhancing patient independence, and reducing healthcare costs. Research shows that when patients are unable to access clinically appropriate home health services, hospital readmissions are 35% higher, mortality rates are 43% greater, emergency department utilization grows by 16%, and total spending is 5.4% more than if patients were able to access the services they need. Protecting this vital benefit is also popular as 70% of U.S. voters are opposed to Medicare home health cuts.

# # #

About the National Alliance for Care at Home

The National Alliance for Care at Home (the Alliance) is the leading authority in transforming care in the home. As an inclusive thought leader, advocate, educator, and convener, we serve as the unifying voice for providers and recipients of home care, home health, hospice, palliative care, and Medicaid home and community-based services throughout all stages of life. Learn more at www.AllianceForCareAtHome.org.

© 2025 by National Alliance for Care at Home. This press release originally appeared on the Alliance website and is reprinted here with permission. For more information or to request reprint permission, please see press contact information above.

Appeals Court Filing

Advocacy
by Kristin Rowan | Dec 4, 2025 | Advocacy, Clinical, CMS, Hospice, Legal

by Kristin Rowan, Editor

Appeals Court Filing

Hospice ALJ

A hospice claim may fall under review either before or after the claim has been paid. A hospice agency with a denied claim must file appeals until the claim is approved or the appeals are exhausted. First, they file a written request to reconsider. Then, they file an appeal to a Qualified Independent Contractor (QIC) who employs medical professionals to assess the case. Next, they file an appeal to an Administrative Law Judge (ALJ).

The ALJ is meant to review the documentation to determine whether it satisfies Medicare requirements. That’s all. There are two sets of criteria: the Medicare requirements and the patient record. If they match, the claim is paid. However, a recent ALJ decision and subsequent challenge suggests that the ALJ ignored expert testimony and decided independently that the patient did not qualify for hospice care.

Request to File

The hospice agency in this case filed suit against the ALJ, arguing that physician expertise should be shown deference in these cases. The National Alliance for Care at Home (the Alliance), joined by the American Academy of Hospice and Palliative Medicine (AAHPM), represented by William A. Dombi of Arnall Golden Gregory (AGG), has requested the right to file an amicus brief. An amicus brief provides extra information in a court case from an individual or group that is not part of the lawsuit, but has a vested interest in the outcome.

The Dispute

The Alliance puts at the heart of the case several issues, including:

Predicting death is inherently difficult

Physicians are the experts and their opinion should carry more weight

Oversight from non-qualified third parties add confusion, increase costs, and limit care

The Argument

The wording in multiple parts of the hospice benefit recognizes the expertise and importance of the physician. It is the physician who determines terminal illness. Physicians must have a face-to-face for continued eligibility. And it is the physician’s clinical judgment makes these determinations based on a patient’s individual circumstances, not an arbitrary set of standards.

If an ALJ, or any non-medical person, can overrule the treating physician’s assessment of a patient, they are effectively usurping the role of the doctor in providing a treatment plan. Medical care is subjective, which is why CMS has repeatedly considered and rejected defined criteria that would overrule a physician.

Broader Implications

The brief argues that medical professionals are better able to make care determinations. Further, the brief includes the complexity of health care prognosis, particularly in terminal illnesses. Previous court decisions have noted that “clinical judgments must be tethered to a patient’s valid medical records….” which already eliminates the need for this oversight. The Alliance stated a high probability that the decision in this case will carry substantial weight and influence both in the Sixth Circuit and in courts nationwide.

In fact, the implications may be farther reaching than that. Payors in and out of hospice deny claims deemed “unnecessary” regularly. Claims denials range from about 19% in the ACA Marketplace to as much as 49% from private payers. Even though about 80% of appeals are later accepted, only about 1% of denied claims are appealed.

Not only could this case help more patients get the hospice care they need, it could also lay the groundwork to require insurance companies to rely more heavily on the treating physician’s recommendation. We could see lower denials from prior authorization requests, unconventional treatment plans, VA benefits, and more.

Final Thoughts

The Rowan Report supports the Alliance’s efforts in this case and wholeheartedly agrees that a physician knows better the care his patient needs than a judge ever could. We are hopeful that Bill Dombi and his team at AGG will be successful in this case and that hospice providers can get back to the business of patient care. Read the statement from the Alliance here.

# # #

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

BREAKING NEWS: Home Health Final Rule

Breaking News
by Kristin Rowan | Nov 29, 2025 | Breaking News, CMS, Home Health, Medicare, Medicare Advantage, Regulatory

by Kristin Rowan, Editor

BREAKING NEWS

Home Health Final Rule

While most of us were still recovering from our Thanksgiving feast overload, CMS quietly released the CY 2026 Home Health Prospective Payment System Final Rule (HH Final Rule). In past years, CMS published the HH Final Rule on or about November 1. The HH Final Rule was delayed this year due to the government shutdown.

Payment & Policy Updates

The payment rate for 2026 will change based on multiple factors:

HH payment update of +2.4%

The final permanent rate adjustment of -0.9%

The final temporary adjustment of -2.7%

Fixed-dollar loss ratio for outlier payments update of -0.1%

The aggregated payment update for 2026 is a net decrease of 1.3%

Read the CMS Fact Sheet

Face-to-Face

The CARES Act allows Nurse Practitioners, Certified Nurse Specialists, and Physicians Assistants to order and certify eligibility for Medicare HH and establish a plan of care. CMS has updated face-to-face encounters to now allow NPs, CNSs, PAs and physicians to perform face-to-face encounters whether or not they were the certifying practitioner or one who cared for the patient prior to home health care.

Home Health VBPM

Effective in April 2026, the HHCAHPS survey will undergo changes. CMS is removing these three survey-based measures:

Care of Patients

Communications between Providers and Patients

Specific Care Issues

CMS is adding four measures to them measure set. These include three measures related to bathing and dressing and the Medicare Spending per Beneficiary setting measure. These changes also prompted alterations to the weights of each measure and measure category.

The expanded model has built-in criteria for the removal of any quality measure. CMS is adding an additional criteria to the list of factors. Factor 9 reads that CMS may remove a quality measure if it is not feasible to implement the measure specificiations.

Medicare Provider Enrollment Revocation

Currently, any provider must enroll and be approved to become a Medicare provider. CMS has the authority to both approve and revoke provider Medicare enrollment. When CMS revokes a provider’s Medicare enrollment, the revocation is effective 30 days after CMS mails notification to the provider. In certain circumstances, CMS can revoke enrollment retroactively to the first date of non-compliance and consequently collect any money paid to that provider back to the retroactive date. CMS is adding to the allowable grounds for retroactive revocation.

If an enrolled physician or practitioner has not ordered or certified services for 12 consective months

If a beneficiary attests that a provider did not actually perform the services they billed

Additional Changes

CMS is recalibrating case-mix weights under PDGM and LUPA thresholds.

DMEPOS accreditation regulations will now require suppliers to be resurveyed and reaccredited annually. Additionally, CMS is increasing the amount and frequency of data accrediting organizations (AOs) submit, expanding their ability to monitor AOs, and strengthening their ability to address poorly performing AOs.

The DMEPOS Competitive Bidding Program will change, but we are still waiting for the finalized improvements. CMS will begin paying for all continuous glucose monitors and insulin infusion pumps.

Read the Final Rule and additional Documents

Final Thoughts

A decrease in pay of any amount is unfortunate. However, we applaud CMS for listening to the feedback. CMS stated, “…commenters raised concers that behavior change after CY 2022 might [attribute] to factors unrelated to…PDGM.” Changes since 2020 include the introduction of OASIS-E, the expansion of value-based purchasing, and the large increase in the percentage of Medicare Advantage enrollees.

Whatever the reason, The Rowan Report joins the National Alliance for Care at Home in commending CMS for adjusting its payment calculations. The permanent pay adjustment for 2026 is listed as the final adjustment, a positive for HH moving forward. The proposed rule issued mid-year had a net -6.4% decrease in payments for a net decrease of more than $1 billion dollars. The final rule payment adjustment has a net decrease of $220 million. Still a decrease, but much more palatable.

CMS will continue to assess the need for temporary payment adjustments for several more years. Additional adjustments (read decreases) to the payment rate will impact patient access to care. The Alliance will continue to advocate and educate members of Congress and HHS to lower or eliminate they reductions. Your advocacy and support is needed to ensure the future of Care at Home. The Rowan Report will continue to support the Alliance and other advocacy groups and share with you opportunities for advovacy.

# # #

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

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