MedPAC Finalizes Recommendation to CMS

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

Alliance to Congress: STOP CUTS

by Kristin Rowan | Oct 30, 2025 | Advocacy, CMS, Home Health, Medicare

by Kristin Rowan, Editor

9% Cut Proposed

CMS proposed home health rule for 2026 includes disastrous cuts. A 3.2% market basket increase, a 0.8% productivity cut, a 5% reduction to recoup prior overpayments, and a 4.1% permanent reduction to prevent further overpayments. CMS proposed an additional 0.5% cut to account for high-risk outliers. In other words, CMS wants to pay less for all patients to make up for the small percentage of patients who need more care.

Deadline Looming

The mandatory comment period ended on August 29. Next, CMS reviews the submitted comments, responds to those comments (generally explaining why they are not going to listen), and then finalizes the 2026 rule. The final rule is due November 1, 2025. Although, that falls on a Saturday, so the deadline may extend to Monday. A good many of us will be in New Orleans for the Alliance annual conference and expo by then.

Group Effort

The National Alliance for Care at Home (Alliance) joined 150+ provider, patient, community, and advocacy groups to write a letter to Congress urging them to prevent the CMS proposed cut.

“The proposed payment reductions for home health pose a serious threat to the health and safety of Medicare beneficiaries and to the broader integrity of our healthcare system. With the 2026 payment rule under review and due by November 1, we urge you to promptly intervene and press CMS to stop the cuts and realign payments.”

Pattern of Payment Reduction

The letter, addressed to Senate Majority Leader John Thune, Senate Minority Leader Chuck Schumer, Speaker Mike Johnson, and House Minority Leader Hakeem Jeffries, asks Congress to look at the consecutive years of pay reductions and how they have impacted home health. Because of the cuts, agencies have gone out of business or downsized, leaving rural areas without care.

Home Health Costs Less

The letter also explains that cutting medicare payments actually costs more. When more patients have access to home health, CMS spends less on unplanned hospital visits and ER trips. Patients have fewer falls and accidents. Risk factors are identified earlier and preventative treatments are used before a patient’s condition requires hospitalization. Home health patients stay home years longer than those not receiving home health before entering a skilled nursing or assisted living facility.

What's at Risk

The Medicare Trust Fund, funded partially by payroll taxes, includes hospital insurance that pays for hospital (Medicare Part A) services. When these costs increase, the trust fund is at risk being insolvent and taxes are increased to put money back into the fund. Lowering home health payment rates and cutting off millions of people who depend on home health will impact tax payers as well.

“The cuts currently proposed to Medicare’s home health benefit are unsustainable and would be deeply harmful to those who depend on care at home. The Alliance will continue to work with policymakers and our stakeholder allies to oppose these harmful cuts and protect access to home health services for millions of older adults, individuals with disabilities, and their families.”

Dr. Steve Landers

CEO, National Alliance for Care at Home

The Alliance issued a press release with the highlights from the letter. You can read the full letter here.

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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

Fraud, Waste, and Abuse

by Kristin Rowan | Jul 10, 2025 | Clinical, CMS, Home Health, Legal, Medicare, Medicare Advantage, Regulatory

by Kristin Rowan, Editor

Fraud, Waste, and Abuse

DOJ, HHS False Claims Act

Fraud, Waste, and Abuse has become something of a mantra within the Department of Health and Human Services (HHS). Secretary Kennedy has committed to combatting fraud, waste, and abuse within the federal healthcare system. The Department of Justice (DOJ) and HHS have a long history of working together to combat healthcare frauding under the False Claims Act (FCA).

Working Group

In furtherance of their goal to combat healthcare fraud, HHS and DOJ have formed the DOJ-HHS False Claims Act Working Group. The Working Group will include leadership from the HHS Office of General Counsel, CMS Center for Program Integrity, the Office of Counsel for the OIG, and the DOJ Civil Division.

Working Group Priorities to Combat Fraud, Waste, and Abuse

1. HHS will refer potential False Claims Act violations to the DOJ that are in line with the Working Group priority enforcement areas:

Medicare Advantage
Drug, device, or biologics pricing
- arrangements for discounts, rebates, service fees, and formulary placement and pricing reporting
Barriers to patient access to care
- violations of network adequacy requirements
Kickbacks related to drugs, medical decives, DME, and other products paid for by federal healthcare programs
Materially defective medical devices that impact patient safety
Manipulation of Electronic Health Records systems to drive inappropriate utilization of Medicare covered products and services

2. The Working Group will maximize collaboration to expedite investigations and identify new leads. They will leverage HHS resources using data mining and assessment of findings.

3. The Working Group will discuss implementing payment suspension according to the CMS Medicare Program Code of Federal Regulations¹

4. The Working Group will discuss whether DOJ will dismiss a whistleblower case under the U.S. Code for Civil actions for False Claims, pursuant to the DOJ Manual for Civil Fraud Litigation²

Report Fraud, Waste, and Abuse

The Working Group encourages whistleblowers to report violations of the False Claims Act within the priority areas. Tips and complaints from all sources about potential fraud, waste, abuse, and mismanagement can be reported to HHS at 800-HHS-TIPS (800-447-8477). Similarly, the Working Group encourages healthcare companies to identify and report such violations.

²DOJ Dismissal of a Civil Qui Tam Action. When evaluating a recommendation to decline intervention in a qui tam action, attorneys should also consider whether the government’s interests are served, in addition, by seeking dismissal pursuant to 31 U.S.C. § 3730(c)(2)(A).

¹Suspension of payment. The withholding of payment by a Medicare contractor from a provider or supplier of an approved Medicare payment amount before a determination of the amount of the overpayment exists, or until the resolution of an investigation of a credible allegation of fraud.

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The Alliance Responds

by Kristin Rowan | Jun 13, 2025 | Advocacy, CMS, Hospice

by Kristin Rowan, Editor

The Alliance Responds to CMS Hospice Update

The Alliance responds to CMS-1835-P, the FY 2026 Hospice Wage Index, Conditions of Participation, and Quality Reporting Program Requirements updates. On June 10, 2025, in a 25 page letter to Dr. Mehemet Oz, CEO for The National Alliance for Care at Home Steve Landers, MD, MPH lays out the constraints and financial burdens hospice agencies will face if these updates are enacted.

Payment Rate Update

Increase Less than Inflation

In the rule for FY 2026, CMS proposes a 3.2 percent market basket increase and a .8 percent productivity decrease, yielding a 2.4 percent increase overall. According to the letter, inflation has raised medical care prices by 3.1 percent, leaving a shortfall of .7 percent. Hospices are also plagued by the same workforce shortage the rest of the medical industry faces. Workforce shortages result in fewer qualified people than there are available positions, which drives wages up. BLS data indicates the wage increase for 2025 was 4.4%. The Alliance argues that the 2.4% net increase falls well short of the actual expense increase.

Faulty Data

In a recent article, we outlined the process that CMS uses to determine the market basket update. The Alliance echos our information, showing the market basket forecast is well below actual increases. The Alliance further argues that the shortfall compounds, leaving the base rate increasingly smaller with each forecast. The current estimate is a 4.9% pay rate gap. CMS contends there is no way to adjust for forecast errors. The Alliance has a simple solution: manually adjust the payment rate every year when the finalized number are above the forecasted numbers BEFORE adding the next year’s payment rate increase.

Likewise, The Alliance concurs with The Rowan Report sentiment that productivity cannot increase in hospice like it does in less labor-intensive sectors. Landers also mentions the failure to consider travel costs, the wage differences in rural areas, and the lack of reclassification options in hospice care.

Payment Rate Recommendations

As any well-drafted response should, The Alliance provides actionable recommendations in each section. For payment rate updates, The Alliance recommends:

We recommend CMS examine closely more recent data and increase final payment rates for FY 2026.
We urge CMS to explore all available avenues to address the forecast error shortfall, such as through a one-time adjustment.
We encourage CMS to collaborate with stakeholders to address the shortcomings of relying upon hospital data to determine hospice payment rates, and ways to achieve parity across provider types with respect to geographic area wage adjustments.

HIS to HOPE Transition

Also addressed in the letter is opposition to the timeline of the HIS to HOPE transition. The Alliance restates much of what was in the joint letter to CMS urging the delay of the HOPE tool adoption. That letter was a joint venture between The National Alliance for Care at Home (The Alliance), LeadingAge, and the National Partnership for Healthcare and Hospice Innovation (NPHI).

The consequence of adverse outcomes cannot be understated. The risk of negative financial consequences for hospice providers is
largely dependent this year on the success of two transitions—iQIES and HOPE— neither of which are within their control.

Steve Landers, MD, MPH

CEO, National Alliance for Care at Home

HOPE Transition Recommendations

Considering the volatility inherent in a reporting transition of this magnitude and the lack of clear information provided to date, we respectfully request CMS waive the HOPE timeliness submission requirement for two calendar quarters post implementation.
We further respectfully request that CMS delay the HOPE implementation date until at least six months after CMS education and training, beyond that which is introductory and that is scheduled for spring/summer 2025, the final validation utility tool specifications are available and the application for iQIES access has been opened for hospices.

Digital and Future Hospice Measurements

Among the digital hospice measurements is an interoperability measurement. The Alliance supports interoperability and data exchange across medical care entities, but stresses to CMS that many hospices do not have digital EHR systems, cannot afford to maintain such systems, and have not received the federal financial support necessary to meet this objective.

The Alliance also objects, not in theory, but in practical application, to the nutrition measure noted in future hospice measures. Nutrition for a hospice patient is vastly different than for other patients and should be implemented as a process measure, rather than having specific goals for food intake and nutrition.

Similarly, the well-being measure is not designed for hospice care. In other sectors of healthcare, well-being incorporates measures for mental, social and physical health and focuses on curative plans. Hospice care focuses on person-centered care, emphasizing the desires of the patient as they are balanced against religious, cultural, and personal beliefs. The well-being measure must be curated to fit hospice care.

The Alliance - Conclusion

The Alliance values CMS’s ongoing commitment to enhancing hospice care quality,
ensuring program integrity, and improving patient outcomes. We appreciate your
consideration of our comments and look forward to ongoing dialogue to achieve these
shared objectives.

The Rowan Report - Conclusion

The Alliance has, as always, done an exemplary job at explaining the industry position on the CMS rule. Likewise, it has outlined each step CMS should take to view the updates through a hospice lens rather than a hospital lens. We commend and support The Alliance statement and position. As this is an ongoing topic until the final rule is implemented, we will continue to provide updates as they become available.

If you are a member of The Alliance, you can read the full 25 page letter here.

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