Alliance Responds to CMS

by Rowan Report | May 14, 2026 | Advocacy, CMS, Medicare, Regulatory, Waste Fraud and Abuse

FOR IMMEDIATE RELEASE

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

The Alliance Responds to CMS’s Announcement of Nationwide Enrollment Moratoria on Hospice and Home Health Providers

Washington, D.C, May 13, 2026. On May 13, the Centers for Medicare & Medicaid Services (CMS) announced a six-month national moratorium on hospice and home health enrollment in response to program integrity concerns within the Medicare programs. While the National Alliance for Care at Home (the Alliance) strongly supports efforts to root out bad actors who exploit these essential programs, undermine confidence in care at home, and threaten the patients and families who depend on it, the Alliance has long advocated for targeted strategies that distinguish between high-fraud markets and communities where fraud is not an identified problem and patients already face shortages of providers.

Concerns

The Alliance welcomes the Administration’s focus on combatting fraud, waste, and abuse and appreciates that CMS has indicated providers will still be able to conduct face-to-face recertification visits via telehealth during the enrollment moratorium, which will help avoid unnecessary care disruptions for patients and families. However, an enrollment moratorium does not distinguish between bad actors and compliant providers and will ultimately reduce competition and slow innovation. More importantly, an enrollment moratorium raises serious access-to-care concerns in areas where patient demand is growing or existing capacity is already strained, leading to longer wait times, reduced service availability, and fewer choices for patients – particularly in rural or underserved communities.

Less Severe Recommendations

Public reports show that fraud is concentrated in specific geographies and among specific actors, signaling that targeted reforms and oversight strategies are needed to identify and remove fraudulent entities from the Medicare program. The Alliance and other national organizations have repeatedly provided CMS with recommendations that focus on preventing bad actors from entering the Medicare and Medicaid programs and better leveraging existing tools to fight fraud without creating unnecessary burden for good-faith providers who are already meeting program requirements.

From the Alliance CEO

“The majority of home health and hospice providers deliver compliant, patient-centered, and clinically appropriate care to individuals with complex needs, often in their most vulnerable moments. CMS must use data-driven, risk-based program integrity measures and focus resources on boots-on-the-ground surveys and enforcement of existing oversight mechanisms that root out the blatantly bad actors without potentially limiting patient access to care or punishing high quality providers operating in good faith.”

Jennifer Sheets

CEO, National Alliance for Care at Home

Final Thoughts

This moratorium, effective May 13, applies only to new providers and certain changes of ownership, and may be extended if CMS deems it necessary.

The Alliance has been and will remain a proactive, constructive partner to Congress and federal regulators on program integrity efforts. The Alliance will continue to engage with the Administration on a path forward that holds bad actors accountable while protecting patient access to the safe, high-quality care at home they need and deserve.

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About the National Alliance for Care at Home

The National Alliance for Care at Home (the Alliance) is the leading authority in 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. 

Medicare Moratoria

by Kristin Rowan | May 14, 2026 | Breaking News, Medicare, Regulatory, Waste Fraud and Abuse

by Kristin Rowan, Editor

Medicare Moratoria

CMS Halts All New Home Health & Hospice Agencies

As part of it’s ongoing efforts to curb Medicare waste, fraud, and abuse, the Centers for Medicare and Medicaid Services (CMS) is taking a bold step. On Wednesday, May 13, 2026, CMS announced a 6-month moratoria on home health and hospice agency enrollment. Aimed at protecting Medicare beneficiaries and taxpayer dollars, the moratoria will temporarily stop new enrollment of providers in home health and hospice, which CMS calls “high-risk” categories and key sources of fraudulent activity. CMS states this effort builds on additional fraud prevention initiatives, including enhanced screening, site visits, and expanded oversight activities across the hospice and home health sectors

More Investigations

Together with Vice President JD Vance’s Anti-Fraud Task Force, CMS will increase its targeted investigations of hospice and home health agencies that are suspected of fraud. CMS promises to use advanced data analytics and to accelerate the removal of fraudulent hospice and home health agencies.

Skirting Authority

CMS investigations revealed that some agencies intent on committing fraud are closing their businesses and reopening under different names in different states to perpetrate additional fraud. The moratoria will prevent these agencies from skirting authority in this manner. Additionally, the moratoria applies to some changes in ownership, which is a common technique used to hide these “bad actors.”

What it Means for You

The moratoria do not apply to existing providers with current enrollments. You can continue to deliver services to Medicare beneficiaries as long as your enrollment is current and in good standing.

Statement from CMS

“We’ve seen systemic and deeply troubling fraud in the hospice and home health space, with bad actors exploiting some of our most vulnerable Medicare patients and stealing money from the American taxpayer. Today we’re shutting the door on fraud—preventing new bad actors from entering Medicare while we aggressively identify, investigate, and remove those already exploiting them. This is about protecting patients, restoring integrity, and safeguarding taxpayer dollars.”

Dr. Mehmet Oz

Administrator, Centers for Medicare and Medicaid Services

More Information

The administration’s anti- fraud, waste, and abuse efforts are ongoing.

Read the CMS Press Release

Full text of the Home Health Moratorium

Full text of the Hospice Moratorium

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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

Accountability and Sustainability in Medicare Advantage

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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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

WISeR Model Not so Wise

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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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

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

LEAD Replaces REACH

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

CMS Proposed Changes

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.

CMS Proposed Changes<br />
Technology-based Care

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.

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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

MedPAC Proposes Drastic Cut

by Kristin Rowan | Dec 12, 2025 | Clinical

by Kristin Rowan, Editor

MedPAC Proposes Drastic Cuts

Five Year Decrease Not Enough

The onset of PDGM and the recalculations of payments in 2020 have led to an overall decrease in Medicare reimbursement rates for home health by approximately 12%. CMS continues to calculate budget neutrality with flawed formulas. The Alliance, along with several other advocacy groups as well as agencies and individuals, continues to fight against the formula and the pay cuts, estimating that nearly half of all home health agencies will be losing money in order to stay open.

Industry Report

Despite the continual decrease in payment rates, MedPAC recommends additional steep cuts. Highlights from the MedPAC report include:

97% of beneficiaries have access to 2 or more HHAs
The total number of HHAs declined 1% in 2024 (excluding CA)
Only 7.9% of beneficiaries used HH in 2024
Number of 30-day periods per beneficiary increased 2.6%
The overall profit margin for Traditional Medicare is 21.2%
The overall profit margin for all payers is 5%
Anticipated profit margin for 2026 is 19% for Traditional Medicare (3% overall)

Less than 0

The Traditional Medicare profit margin in 2026 is projected at 19%. This is offset by the negative profit margin from Medicare Advantage and private insurance plans. It may not be realistic or fair for the taxpayer to offset poor policies in Medicare Advantage and private insurance plans, but that has been the reality for years. Medicare Advantage plans yield high profits for insurance payors, and negative margins for HHAs. With an overall profit margin of 3%, lowering the Medicare reimbursement rate by more than 3% will put all HHAs in the red.

The Math Isn't Mathing

The numbers are there. HHAs earn 5% now, 3% next year. MedPAC recommends that CMS reduce the 2026 rate by an additional 7%.

NET PROFIT MARGIN -4%

Conclusion from MedPAC: This will not impact care; providers will still be willing to treat Traditional Medicare beneficiaries.

That statement may be true. However, in order for HHAs to survive, they will have to drop all MA plans. More than 50% of Medicare beneficiaries are on MA plans. 40% of MA patients use HH care after hospitalization. Medicare Advantage will survive through hospitals and physicians, but the Home Health benefit won’t have any providers.

Hospice Tie-In

CMS is currently weighing the option of the hospice carve-in to Medicare Advantage plans. The pilot plan failed miserably and yet rolling this out across all plans is an option, somehow. CMS and MedPAC must not be able to see what has happened to Home Health under MA plans. Hospice will suffer the same fate through the carve-in. It is irresponsible and destructive to add Hospice to MA. For that matter, it is irresponsible and destructive NOT to remove Home Health from MA. Move it all back to Traditional Medicare where at least the profit margin is above 0.

May Cooler Heads Prevail

From the proposed rule in July to the final rule in November, CMS lessened the permanent rate cut by about 5%, finally hearing the concerns of advocates who told them HHAs would go out of business. We certainly hope CMS will keep that in mind when considering the MedPAC recommendation.

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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

Feedback Adjusts Final Rule

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.

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About the National Alliance for Care at Home

The National Alliance for Care at Home (the Alliance) is the leading authority in 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

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.

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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