Medicare Home Health Cuts: Survey Says

by Rowan Report | Sep 4, 2025 | Partner News

FOR IMMEDIATE RELEASE

Contact: Elyssa Katz
571-281-0220
communications@allianceforcareathome.org

70% of Americans Oppose Medicare Home Health Cuts, National Poll Finds

Alexandria VA, and Washington, DC, September 4, 2025– A new national poll by Fabrizio Ward, commissioned by the National Alliance for Care at Home (the Alliance), finds that seven in ten Americans oppose the Centers for Medicare & Medicaid Services’ (CMS) 2026 Medicare home health proposed rule, which would slash Medicare home health funding by an additional 9%, or $1.1 billion, next year. These cuts would put lifesaving home health care for millions of Americans at risk, particularly seniors and those with disabilities, while doing nothing to address fraud, waste, and abuse occurring in the home health payment system.

In one of the strongest bipartisan rebukes of Medicare home health cuts to date, the poll found overwhelming opposition across party lines. Large majorities of voters support targeting cost savings to eliminating waste and fraud rather than across-the-board cuts. Voters widely recognize that home health provides significant savings for taxpayers, that lack of access to home health due to recent cuts hurts Medicare patients, and that many more would be hurt if the proposed cuts go into effect.

“The results send a crystal-clear message: Americans want more home-based care, not less, and preserving access to care is critical. Cutting home health doesn’t save money – it hurts patients, worsens outcomes, and costs taxpayers more in the long run.”

Dr. Steve Landers

CEO, National Alliance for Care at Home

The poll reveals Americans see home health as essential to keeping patients safe at home, lowering costs, and easing pressure on already overburdened hospitals and emergency rooms.

Key findings:

70% of all voters oppose Medicare cutting home health services by an additional 9% next year.
91% of all voters believe it’s important that home health services be available when Medicare patients require extra medical support.
55% of all voters support President Trump taking steps to reverse the proposed Medicare home health cuts and ordering a crackdown on fraud in the system.
71% of all voters believe home care is the most affordable care option, compared to just 17% who believe hospital care is more affordable.
73% of all voters say that cutting Medicare home health harms patients and legitimate providers while failing to stop the fraudulent operators that scam hundreds of millions of dollars from the program each year is a good reason to oppose the cuts.

“With more than one out of every two voters either on Medicare, or with a parent on Medicare, voters are clear that people want treatment at home if it’s an option and that home medical care is less expensive than care provided at hospitals and nursing homes. Voters also see the folly in across-the-board cuts that harm everyone rather than focusing efforts to root out known fraud in the home health system. Across the political spectrum voters oppose cuts and support redoubling efforts to fight fraud.”

Tony Fabrizio

Partner, Fabrizio Ward

“These numbers should give every lawmaker pause,” Dr. Landers cautioned. “Patients want to recover where they’re safest – at home. It’s time for Congress to protect what’s working and stop the home-care bleeding. Lawmakers have an opportunity to protect a program that saves lives, lowers costs, enjoys overwhelming bipartisan support, and reflects the clear will of the American people.”

The Alliance is urging Congress and CMS not to finalize the proposed payment cuts and to work with providers to revise their approach and strengthen, not weaken, access to home-based care.

A memo of the poll findings can be found here.

###

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 Advantage Excess Payments

by Kristin Rowan | Sep 4, 2025 | CMS, Hospice, Medicaid, Medicare Advantage

by Kristin Rowan, Editor

Medicare Advantage Excess Payments

Investigational Study

Researchers from the Department of Health Services, Policy and Practice at Brown Universchool of Public Health and the Department of Geriatrics and Palliative Medicine at Icahn School of Medicine published an original investigative study on spending versus payments in Medicare Advantage under the hospice carve-out model.

Carve-out to VBID to Carve-out

In 2021, CMS started a Value-Based Insurance Design (VBID) to test the impact of adding hospice services to Medicare Advantage benefits. By December of 2024, CMS ended the program due to widespread upset. CMS returned to the hospice carve-out model. Under this model, when an MA beneficiary chooses hospice, any health care expenses related to the terminal illness is paid on a fee-for-service (FFS) basis. MA no longer receives inpatient and outpatient payments, but continues to receive premiu, and rebate payments.

Carve-out Hospice Benefit

Once an MA enrollee enrolls in hospice, MA is no longer responsible for payments. Under the carve-out model, hospice services are paid by Medicare. MA plans are still responsible for paying for services that are not related to hospice care. These services can include inpatient, outpatient, physician, skilled nursing facility, home health care, and prescription drug expenses.

Medicare Advantage Spending and Payments

The study spanned 12 months and looked at 314,087 MA beneficiaries. In that period, 80.5% of enrollees had no spneding unrelated to their terminal illness. MA was not responsible for any healthcare related payments, but continued to receive $120 per enrollee per month. Estimated spending from MA on hospice enrollees was $57-70 per month.

In the 12 months following an enrollee electing hospice, MA plans netted $50-60 per month per enrollee. If half of the rebate payments received pay for supplemental benefits, MA receives excess payments to the tune of $68,808,924 over three years. If no rebate payments go toward supplemental benefits, MA receives $174,185,112 in excess payments over three years. The care a hospice enrollee receives uses the fee-for-service model. Medicare Advantage providers are seemingly paid on a fee-for-no-service model.

Medicare Advantage plans do not currently report the actual amount of rebate payments used to pay supplemental benefits.

Study Conclusion

The researchers conclude that MA receives excess payments under the hospice carve-0ut model. They also note that there is no accountability for spending after hospice election from MA plans to CMS. The researchers suggest that CMS could require MA plans to report actual spending on supplemental services after hospice election and pay premiums and rebates only to cover the amount spent.

I have a different recommendation….MA plans should not receive any additional premium payments or rebates following hospice election. MA plans should be required to report total payments and spending from enrollment date to election date. The balance, less the same 8% average margin of home and health and hospice agencies, should be used to pay for hospice services from election to passing. Any remaining balance after the patient’s passing should be returned to the beneficiary’s family.

# # #

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: CMS Changes AHEAD

by Rowan Report | Sep 4, 2025 | CMS, Medicaid, Medicare

From cms.gov

CMS Changes AHEAD

CMS Announces Changes to Achieving Healthcare Efficiency through Accountable Design (AHEAD) Model to Improve Quality, Promote Transparency, and Decrease Costs

September 2, 2025

What's New

The CMS Innovation Center announced new policy and operational changes, as well as a new end date, to the Achieving Healthcare Efficiency through Accountable Design (AHEAD) Model to help states achieve their total cost of care (TCOC) targets, while advancing the Center’s commitment to promote choice and competition, increase prevention, empower patients, and protect taxpayer dollars.

Why it Matters

Participating states now have more tools to manage Medicare costs (designed to support sustainable growth) and improve quality of care and population health outcomes

What to Expect

Changes will be implemented across all cohorts beginning in January 2026. AHEAD’s end date for all cohorts is now December 31, 2035.

The Big Picture

Changes made to the model will help to advance the CMS Innovation Center’s strategic pillars of: 1) choice and competition, with states implementing at least two policies focused on promoting choice and competition in their health care markets and 2) prevention, with a new Population Health Accountability Plan focused on preventive care, including chronic disease prevention.

Additional Details

CMS is also introducing payment reforms through AHEAD for patients with Original Medicare and establishing new transparency requirements around TCOC and primary care investment targets. For the first time ever, AHEAD will bring total cost of care accountability to all Original Medicare beneficiaries in AHEAD regions through geographic attribution of beneficiaries not attributed to other CMS accountable care organization programs. This novel framework will offer risk-bearing Geographic Entities additional tools and enhanced flexibilities to improve health outcomes and lower spending for their patients while receiving shared payments (or losses) through two-sided risk arrangements. In return, patients may receive additional beneficiary incentives while enjoying existing protections under the Original Medicare program.

Total Cost of Care Model

The AHEAD Model is a state total cost of care (TCOC) model that seeks to drive state and regional health care transformation and multi-payer alignment, with the goal of improving the total health of a state population and lowering costs. Under a TCOC approach, a participating state uses its authority to assume responsibility for managing health care quality and costs across all payers, including Medicare, Medicaid, and private coverage. States also assume responsibility for ensuring health providers in their state deliver high-quality care, improve population health, offer greater care coordination, and promote healthier living for all people participating in the model. The AHEAD Model provides participating states with funding and other tools to address rising health care costs and improve health outcomes.

More Information

# # #

Medicare Prior Authorization

by Kristin Rowan | Sep 4, 2025 | CMS, Medicare, Regulatory

by Kristin Rowan, Editor

Medicare Prior Authorization

Wasteful and Inappropriate Service Reduction Model

The Centers for Medicare and Medicaid Services (CMS) is launching a pilot program in six states to combat what they deem to be unnecessary treatments. Dubbed the Wasteful and Inappropriate Service Reduction (WISeR) Model, the voluntary program will launch in New Jersey, Ohio, Oklahoma, Texas, Arizona, and Washington beginning January 1, 2026 and ending December 31, 2031. The program will use Artificial Intelligence (AI) and Machine Learning (ML) alongside human clinical review to “ensure timely and appropriate Medicare payment for select items and services.”

The Problem

According to CMS, health care waste harms patients and comprises 25% of healthcare spending. “Low-value” services provide little effectiveness, do not align with specific health conditions, and can lead to additional complications and more wasteful services.

Medicare Prior Authorization Solution

The new WISeR Model is designed to reduce unsupported care. Participating care providers will outsource authorization of a pre-selected list of services to reviewers using technology to “expedite and improve the review process.” These services are those that CMS designated as vulberable to fraud, waste, and abuse.

Reasoning

CMS suggests that the fee-for-service model used in traditional Medicare incentivizes unnecessary treatments, tests, and other care. According to CMS, these items provide little to no benefit for some patients. These include:

Skin and tissue substitutes
Electrical nerve stimulator implants for obstructive sleep apnea and incontinence
knee arthroscopy for knee osteoarthritis
Cervical fusion
Epidural steroid injections
Vertebral augmentation
Image-guided lumbar decompression
deep brain stimulation for Parkinson’s and essential tremor

Strategy and Outcomes

The WISeR Model is supposed to ensure patients get the most appropriate care for the best outcomes. It is also supposed to lower costs and administrative burden on providers. Patients are supposed to partner with their health care providers to decide on the most appropriate care plan. Eliminating “unnecessary” services and procedures is supposed to save taxpayer dollars and decrease fraud, waste, and abuse. Care providers are supposed to focus on providing care that has the most impact on the well-being of Medicare beneficiaries.

Editorial Comment

I am not a Medicare recipient, but I have many close friends and family who are. I am not a nurse or home health expert, but I am a patient and by my count, I have a PCP and 6 specialists that I see on a regular basis. However, I am now, or will be in the near future, in need of:

Electrical nerve stimulator
Cervical fusion
Steroid injections
Lumbar decompression

Personal Experiences

I am already at the mercy of my health insurance provider for pre-authorizations for everything that is not routine visits with my primary care provider. I know first-hand the hoops and red tape my provider(s) go through. Already this year, I have filed two requests to review denials, more than 10 rescheduled visits because my pre-authorization had not been received, and at least one interview that my PCP had to attend with an “expert” who had previously decided that my regularly scheduled follow-up cancer scan was unnecessary.

Predicted Results

Adding prior authorization approval requirements for care and treatment will delay beneficiaries from getting the care they need, prolong the pain they experience daily, and cost more in wasted time and money than it can possibly save in wasted procedures. I sincerely hope there are enough voluntary participants in this experiment to document the additional time, money, and resources required. I also hope these participants send regular surveys to their Medicare beneficiaries to ask whether they feel like getting pre-authorizations for routine procedures has made them feel like they are getting better care.

# # #

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

OASIS-E2

by Kristin Rowan | Aug 28, 2025 | CMS, OASIS, Regulatory

OASIS-E2

by Kristin Rowan, Editor

OASIS-E2 Instruments and Change Table draft are available from The Centers for Medicare & Medicaid Services (CMS). They are available for download here. The draft proposes an off-cycle implementation date of April 1, 2026

Change Table

Changes include:

Transportation listing changed from A1250 to A1255
Hearing (B0200) and Vision (B1000) added to ROC
Sex (A0810) replaces Gender (M0069)
COVID vaccination up to date removed
Language (A1110) added to ROC
Minor changes to replace outdated item numbers with updated ones (ex: all instances of A1250 changed to A1255)

Change Timeline

The Changes are effective April 1, 2026. However, the changes are not final pending approval from the Office of Management and Budget (OMB). Agencies are able to use the draft form for training purposes, but should look for the final form that includes the OMB control number and expiration date.

Implications

OASIS accuracy is linked to PDGM payments and quality outcomes. Prepare early for the off-cycle April 1, 2026 changes to ensure a smooth transition to E2 requirements and continued reporting accuracy.

Resources

Draft versions of the instruments are on the CMS website in a ZIP file. You can download the file here.

The PRA package, which includes four separate documents, is available for download here.

Submit comments to CMS about OASIS-E2 or any other item in the Home Health Prospective Payment System Rate Update for CY 2026 here and here.

Medicaid Enrollees Sent to ICE

by Kristin Rowan | Aug 21, 2025 | Legal, Medicaid, Regulatory

by Kristin Rowan, Editor

UPDATE

The Rowan Report originally published this article on August 7, 2025. This update is as of August 15, 2025.

After HHS began providing access to personal data on Mediciad enrollees to the Department of Homeland Security (DHS), 20 states filed to sue the department for violating privacy laws. Shortly thereafter, CMS entered into a new agreement to give DHS daily access to view the same data.

Federal Judge Vince Chhabria of California ordered HHS to stop giving DHS access to personal information. The ruling grants a preliminary injunction, stopping HHS from sharing Medicaid data with ICE in the 20 states that participated in the lawsuit. The injunction will last until 14 days after the two agencies complete and submit a reason for the decision to share information. The reasoning must comply with the Administrative Procedure Act. The injunction can also end if litigation is concluded (a formal hearing and decision).

Chhabria noted that there is no formal law preventing government agencies from sharing information, he cited agency policy as his reasoning for the injunction. ICE has a well-publicized policy against using Medicaid data for immigration enforcement. Judge Chhabria wrote in his ruling:

“Given these policies, and given that the various players in the Medicaid system have relied on them, it was incumbent upon the agencies to carry out a reasoned decisionmaking process before changing them. The record in this case strongly suggests that no such process occurred.”

August 7, 2025

Associated Press Confirms

Enrollee Information Given to ICE

In a surprise announcement on July 17, 2025, investigative reporter Kimberly Kindy and reporter Amanda Seitz filed a report. They uncovered information confirming Medicaid enrollee information given to ICE from CMS. ICE will use this to find “aliens” across the country. The health and personal information disclosed includes home addresses, birth dates, Social Security numbers, and ethnicities.

Department of Homeland Security Responds

DHS Assistant Secretary Tricia McLauglin said, “…CMS and DHS are exploring an intitiative to ensure that illegal aliens are not receiving Medicaid benefits….”

DHS Spokesperson Andrew Nixon said, “With respect to the recent data sharing between CMS and DHS, HHS acted entirely within its legal authority—and in full compliance with all applicable laws….”

Opposing Viewpoints

Senator Adam Schiff (D-CA) said, “The massive transfer of the personal data of millions of Medicaid recipients should alarm every American. This massive violation of our privacy laws must be halted immediately. It will harm families across the nation and only cause more citizens to forego lifesaving access to health care.”

Similarly, CA Governor Gavin Newsom said, “This potential data transfer brought to our attention by the AP is extremely concerning, and if true, potentially unlawful….”

HHS and DHS Sued

State Attorneys General from 20 states, led by California Attorney General Rob Bonta have filed suit. They are suing the Department of Health and Human Services (HHS), the Department of Homeland Security (DHS), HHS Secretary Robert F. Kennedy Jr., and DHS Secretary Kristi Noem.

The Associated Press found a Medicaid internal memo and emails. Subsequently, the AP reported that Medicaid officials tried to stop the data transfer due to legal and ethical concerns. The objection was unsuccessful. CMS had 54 minutes to comply with an order coming from two advisors within Secretary Kennedy Jr’s camp.

Disclosure Focuses on Violation of Laws

Current laws provide that states can create their own health plans, eligibility standards, and coverage, as long as the plan follows federal criteria. Medicaid laws also provide for emergency coverage for non-citizens. Seven states and D.C. started programs that offer full Medicaid coverage to non-citizens.

Four of the seven states, New York, Oregon, Minnesota, and Colorado, never submitted identifiable information about Medicaid recipients to CMS. The data shared with ICE came from the remaining three states; California, Illinois, & Washington State; and Washington D.C.

Map of U.S. States Compromised by CMS and DHS

The Allegation

The lawsuit was filed in the U.S. District Court for the Northern District of California. It alleges that the federal government is allowing the personal data of Medicaid recipients to be used for purposes unrelated to the Medicaid program.

Further, the coalition of states alleges that the disclosures violate several federal data privacy laws. These include Health Insurance Portability and Accountability Act (HIPAA), Federal Information Security Modernization Act (FISMA), and the Privacy Act.

Additionally, the Attorneys General state that the disclosures are contrary to the Social Security Act and a violation of the Spending Clause.

The lawsuit calls upon the court to bar CMS from sending additional PII to DHS and to bar DHS from using any of the information it has already received.

“In the seven decades since Congress enacted the Medicaid Act to provide medical assistance to vulnerable populations, federal law, policy, and practice has been clear: the personal healthcare data collected about beneficiaries of the program is confidential, to be shared only in certain narrow circumstances that benefit public health and the integrity of the Medicaid program itself.”

Attorneys General

Coalition of States

Final Thoughts

This lawsuit is the latest of many against the current administration. The Rowan Report will continue to update this and other stories impacting care at home as the lawsuits continue.

# # #

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

Alliance Responds to Hospice Final Rule

by Kristin Rowan | Aug 7, 2025 | Advocacy, CMS, Hospice, Medicare, Medicare Advantage, Regulatory

by Kristin Rowan, Editor

The Alliance Responds to CMS Hospice Final Rule

CMS Issues FY 2026 Hospice Final Rule

On August 1, 2026, CMS issues the FY 2026 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Programs Requirements Final Rule. Here are the high-level changes in this year’s final rule:

Rate Setting Changes
- A 3.3% inpatient hospital market basket percentage increase
- A 0.7% productivity adjustment (read decrease)
- Statutory cap increases from $34,465.34 to $35,361.44
Hospice Care Admission
- The physician member of the interdisciplinary group (IDG) may recommend admission to hospice care
Face-to-Face Attestation
- Signature and date requirements restored
- Eliminated requirement for attestation to be a separate and distinct document
- Attestation requirement can be a section or addendum to recert form, or part of a signed and dated clinical note
Hospice Quality Reporting Program

The HOPE tool will replace the HIS tool on October 1, 2025, despite comments to delay implementation
CMS published a HOPE Technical Information webpage ,an HQRP training library, and a Requirements and Best Practices webpage
CMS recognized the error in their HOPE burden calculations. The burden is 21.1% higher than initially reported. The difference will be “taken into consideration” in the next PRA package submission.
The separate reporting tool (QIES) and reports tool (CASPER) will sunset and iQIES will replace both tools.

FY 2026 Hospice Quality Reporting Program

National Alliance for Care at Home Statement

After CMS issued the final rule, the Alliance responds with a statement addressing the wage adjustment, HOPE tool implementation, and sttestation changes. Read the full press release here.

Wage Adjustment

The Alliance recognizes that the 2.6% wage update is higher than the proposed 2.4% adjustment issued earlier this year. However, The Alliance maintains its position that the update does not go far enough to offset the very high and very real operational costs that hospices across the country face.

Regulatory Relief

Both the physician member of the IDG recommending hospice admission and the inclusion of a clinical note to serve as attestation of a face-to-face were welcome changes to hospice regulations. The Alliance thanked CMS for these changes.

HOPE Tool Implementation

The Alliance was among the many commenters to CMS about the October 1, 2025 implementation date for the HOPE tool. Alliance CEO Dr. Steve Landers had this to say:

Despite responsiveness in other areas, the Alliance is deeply disappointed that CMS did not heed recommendations and delay the October 1, 2025 implementation of the Hospice Outcomes and Patient Evaluation (HOPE) tool nor waive the timeliness completion requirement for HOPE record submission. We expect providers to face a burdensome transition and urge CMS to remain responsive to real-world challenges, offering flexibility as providers navigate the change.

Dr. Steve Landers

CEO, National Alliance for Care at Home

The Alliance is committed to working with CMS to reduce spending and strengthen the Medicare hospice benefit. They also continue to support the CMS initiative to reduce fraud, waste, and abuse.

Final Thoughts

The Hospice Final Rule is not what we hoped for. The wage update was increase, but not by enough to make a real impact on the operational burden hospices face. CMS has provided technical training and education for the HOPE tool, but severely underestimated the financial burden connected to the transition. CMS continues to use outdated, incorrect, or faulty information in its calculations of wage rate updates and ignores the repeated comments from advocacy groups and hospice providers.

# # #

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

Tell CMS not to Kill Home Health

by Kristin Rowan | Aug 7, 2025 | Advocacy, CMS, Regulatory

by Kristin Rowan, Editor

The Alliance to Care at Home:

CMS needs your comments

CMS needs your comments on the home health proposed rule for FY 2026. Advocacy is a cornerstone of the mission of The National Alliance for Care at Home. From The Hill to the home, The Alliance fights for the future of the industry. But, they can’t do it alone.

Proposed Rule

The CMS proposed rule for FY 2026 has a net 6.4% decrease in payments to home health providers. Industry experts warn that this change will cause home health agencies to shutter their doors and it will leave many rural areas in a home health desert.

The Alliance Call to Action

At last week’s 2025 Financial Summit in Chicago, policy and industry experts provided ways to adjust how to write comments to CMS. According to Mary Carr, Vice President for Regulatory Affairs at National Alliance for Care at Home, it’s not enough for a few agencies and organizations to advocate for home health. Everyone has to submit comments about this. Carr says if done effectively, sending comments on proposed rules is one of the most powerful ways to stop these policy changes. The way you write your comment letters is important if you want them to have an impact.

Carr provided this guidance and tips on how to right an effective comment to CMS:

Remember that CMS is not looking for an agree/disagree statement

Provide good reasons for not keeping the proposed rule as is

Address very specific reasons why any part of the proposed rule is bad

Include the direct impact the proposal will have on your business, your staff, and your patients

Provide an alternative recommendation

Mention studies on how much less home health costs compared with SNFs and ALFs

Don’t let fear, anger, and anxiety detract from your message

Maintain professionalism and respect

Mention and thank CMS for any good aspects of the proposed rule

Include impact statements on reduction in services, delays to getting care, and areas that would be without any available home health care should the proposed rule stand

Mention the Other Side

No matter what side of the aisle you are usually on, we all must agree that care at home is an industry issue, not a Democrat or Republican issue. Hillary Loeffler, Vice President of policy and regulatory affairs at the Alliance, reluctantly mentions that the clawbacks, reductions, and methodology used to determine rates were put in place by the previous administration.

“It’s a new administration. I hate to say it, but I’m going to say, ‘This methodology was created by the Biden administration, and the Trump administration needs to do something about this.’ So, hopefully they take a fresh look at it.”

Hillary Loeffler

Vice President of Policy and Regulatory Affairs, National Alliance for Care at Home

Loeffler also suggests going directly to Congress with comments and letters in addition to CMS. The recent trend of lowering reimbursement rates causing fewer visits, less coverage, and longer wait times is untenable and complete reform of the home health benefit at the federal level is needed to ensure its survival, added Loeffler.

Illogical Arguments

Whether you are publishing comments on the home health proposed rule or writing a letter to your senators and representatives, steer clear of logical fallacies. These errors in reasoning are easy to fall prey to when you have an emotional investment in the issue at hand.

Ad Hominem

The very common Ad Hominem fallicy happens when the argument moves from the problem to the person. Blaming your representative or accusing CMS of hating home health rather than focusing on the impact of the pay cut will weaken our standing.

Slippery Slope

This fallicy involves stretching the consequences of an action beyond reality. Cutting home health payment rates will decrease care and increase start-of-care delays. It will not cause homelessness, mass hysteria, or a small pox outbreak.

Fallacy of Composition

If you’re familiar with standard contracts, you’ve read the clause that goes something like, “if any part of this contract is illegal, the rest is still intact.” The composition fallacy assumes that the whole of something matches its parts. The CMS proposed rule for FY 2026 has improvements, such as allowing physicians to do face-to-face appointments even if they are not the certifying physician. Don’t throw out the entire proposed rule. Rather focus on those parts that are clearly devastating to the industry.

Fallacy of Origin

Criticizing the rule based on its authors (CMS) as adversaries to care at home also negates the impact of our advocacy. CMS has been charged with maintaining government payments for health care in hospitals, physician groups, hospices, SNFs, and more. They have also been directed to cut costs, decrease spending, and maintain budget neutrality. The proposed rule is a death sentence for home health not because it came from CMS, but because of the flawed math. Address the calculations, the methodology, the assumption that care at home is more expensive than hospital or SNF care, and the number of people who will lose access to quality care.

CMS needs your comments now

Now that you know what issues to address and how to frame your argument, reach out. Contact CMS and your Congresspeople and submit your comments today. Comments are due by August 29th.

# # #

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

Non-Compliance Notifications & HOPE Training

by Kristin Rowan | Jul 24, 2025 | CMS, Hospice

by Kristin Rowan, Editor

Hospice Non-Compliance Notifications

On July 21, 2025, the CMS Hospice QRP Announcements page added an update titled “Hospice Quality Reporting Program: Non-Compliance Notifications.”

The Update Reads:

The Centers for Medicare & Medicaid Services (CMS) is providing notifications to hospices that were determined to be out of compliance with Hospice Quality Reporting Program (HQRP) requirements for calendar year (CY) 2024…. This will affect their fiscal year (FY) 2026 Annual Payment Update (APU). The Medicare Administrative Contractors (MACs) will distribute Non-compliance notifications and place them into hospices’ Certification and Survey Enhanced Reporting (CASPER) folders in QIES on July 21, 2025. Hospices that receive a letter of non-compliance may submit a request for reconsideration to CMS via email no later than 11:59 pm, August 26, 2025. If you receive a notice of non-compliance and would like to request a reconsideration, see the instructions in your notification and on the Reconsideration Requests webpage.

Details

Any reconsiderations containing protected health information (PHI) will not be processed. All PHI must be removed for a reconsideration to be reviewed.

Additionally, all submissions must be less than 20 MB overall (email message and attachments). Submissions that are greater than 20 MB in size cannot be processed.

HOPE Training

As the implementation date for the HOPE tool drew nearer, advocacy groups and hospice agencies expressed concern over it’s readiness. On June 6, 2025, The Rowan Report shared that three of the largest organizations urged CMS to delay the tool. The groups asked for proper information, education, and training.

CMS Response

As of now, CMS is not delaying the implementation of the HOPE tool. They have, however, published training tools for hospice providers. The first series of videos is Didactic Training. They cover an introduction to the tool, admin information, preferences and active diagnoses, health conditions, skin conditions, and medications.

On July 21, 2025, CMS announced the opening of registration for live HOPE training. “Hospice Outcomes and Patient Evaluation (HOPE) National Implementation Virtual Training Program Course 2: Coding Workshop.” CMS recommends completing The Didactic Training as a prerequisite to the Coding Workshop.

The Centers for Medicare & Medicaid Services (CMS) is offering a live coding workshop on August 5, 2025…. It will provide coding practice for items that are new for HOPE, as well as the existing and updated items carried over from the Hospice Item Set (HIS).

Register now at:The Hospice Outcomes and Patient Evaluation (HOPE) National Implementation Coding Workshop

Find the Didactic Recorded Training Series here.

Data Collection Starts Soon

The HOPE tool begins data collection on October 1, 2025. Key items hospice providers should understand:

More Frequent Assessments: HOPE introduces up to four assessment points per patient, capturing care from multiple angles during the first 30 days and at discharge.
Real-Time Data Capture: Unlike the retrospective nature of HIS, HOPE assessments are completed during live patient encounters, providing richer and more immediate insights.
Higher Stakes for Compliance: To avoid a reimbursement cut of up to 4%, agencies must ensure that at least 90% of HOPE assessments are submitted on time—a notable increase from the previous 2% penalty under HIS.
Public Reporting Timeline: While HIS data has been publicly available, HOPE data will not be released for public comparison until fiscal year 2028 or later, giving providers time to adapt.

*from the SimiTree blog: Understanding the Transition from HIS to HOPE

As the implementation of the HOPE tool gets closer, we will continue to share training information from CMS and other sources as it becomes available. If you need a referral to a hospice consultant to navigate the transition, please reach out to The Rowan Report.

# # #

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

Impact of H.R. 1: The Homebound and Overlooked

by Tim Rowan | Jul 24, 2025 | Medicaid, Regulatory

Analysis by Tim Rowan, Editor Emeritus

The Impact of H.R. 1

Homebound and Overlooked

In early 2025, the Republican-led Congress introduced its proposed budget for FY2026 and beyond, a sweeping legislative effort aimed at curbing federal expenditures and restructuring entitlement programs. Medicaid, one of the largest healthcare safety nets in the United States, faces major revisions under this bill. Central to the proposed changes is the shift toward block grants or per-capita caps on federal funding. The legislation also rolls back incentives enacted into law by the Affordable Care act, including those that supported Medicaid expansion. The reconciliation bill, signed into law on July 4, also eliminates financial support for optional services such as home and community-based services (HCBS). A new set of work requirements in the new law will expand the paperwork burden for beneficiaries.

Risks for Home- and Community-Based Care

The figure below presents a visual from the Commonwealth Fund showing their projection of over $100 billion in cumulative federal Medicaid cuts by 2035. These reductions are expected to disproportionately affect non-mandated programs like HCBS, which are many times more economical than residential care. With diminished federal support, states will face pressure to reallocate limited resources, often at the expense of these optional, yet critical, programs. ¹

For nearly eight million elderly Americans, Medicaid-funded HCBS has helped reduce hospital admissions, extend independence, and relieve stress on long-term care facilities. However, the new budget cuts destabilize these programs. Barbara Merrill, CEO of ANCOR, expressed concern, stating, “When you cut federal Medicaid dollars, even for optional services, states have to make tough decisions about who gets care and when.”² Experts anticipate that approval delays, extended waitlists, and even termination of services could follow as states struggle to maintain existing infrastructure.

Comparing the 2005 Budget Bill to the Affordable Care Act

Compared to the Affordable Care Act (ACA), the Republican budget bill marks a significant policy reversal. The ACA expanded Medicaid eligibility and incentivized states to develop non-institutional care models. It emphasized preventive care and home-based treatment options, helping shift care away from costly institutional settings. By contrast, the new bill eliminates such incentives and introduces fiscal and operational barriers. According to data from Medicaid.gov and the Kaiser Family Foundation, Medicaid enrollment, which rose steadily during the ACA years, is projected to drop by 10% nationwide once the budget bill is implemented³. This decline reflects both tightening eligibility and retreat from HCBS programs.

Healthcare providers will need to brace for substantial ripple effects. With fewer patients accessing home care, hospitals and emergency departments may see an uptick in acute episodes related to unmanaged chronic conditions. Providers may also encounter staffing shortages and reduced reimbursements, undermining service quality and sustainability. Richard Edwards, policy director at Amivie Home Health, warned, “If states cut home care services, many patients have no other choice but to enter a skilled nursing facility. That’s not just a shift in care—it’s often a worse outcome at a higher cost.” ⁴ These operational challenges could exacerbate pressure on an already strained healthcare workforce.

Scope and Severity of Coming Changes

Today, over eight million seniors rely on Medicaid-funded HCBS, with an average annual cost per recipient of $29,000. Thirty-three states use HCBS waivers to administer these services, yet the average state waitlist already exceeds 3,000 applicants. Institutional care costs remain 57% higher than home care, making HCBS not only more humane but more fiscally prudent. Despite that, projected federal cuts of $100 billion by 2035 threaten to replace HCBS with nursing home care. Meanwhile, a national enrollment drop of 10% would leave millions at risk of losing coverage and care.

Richard Edwards, policy director at Amivie Home Health, explains, “If states cut home care services, many patients have no other choice but to enter a skilled nursing facility. That’s not just a shift in care—it’s often a worse healthcare and social outcome at a higher cost.” ⁴

8 million elderly rely on Medicaid HCBS
$29,000/year average cost per Medicaid home care recipient
33 states use HCBS waivers
Average state waitlist for HCBS exceeds 3,000 applicants
Institutional care costs 57% more than home care
Estimated federal Medicaid cuts by 2035: $100 billion
Projected national enrollment drop: 10%

Implications for Care at Home: Next Steps

To mitigate these risks, policy experts are advocating for pragmatic alternatives, knowing that implementation depends entirely on the direction in which political winds blow. Federal stabilization grants could offer targeted relief to states with high HCBS enrollment, preserving continuity of care. Streamlining waiver approvals would reduce bureaucratic delays and ease access for both providers and patients. Retaining key ACA incentives could help maintain momentum in home-based care innovation. States would also benefit from flexible financing rules, including reformed provider tax policies, to better manage Medicaid funds under new constraints.

Final Thoughts

Ultimately, the new budget, passed with no Democratic votes, may reshape eldercare delivery for years to come. With states facing hard choices, the healthcare community must prepare for transitions that could disrupt care and deepen inequities. Advocacy for vulnerable populations, investment in alternatives, and ongoing engagement in policy reform will be essential to ensure seniors receive the care they deserve in the setting they prefer.

# # #

____________________________________________

¹ Congressional Budget Office, Federal Healthcare Outlook 2025–2035
² Barbara Merrill, ANCOR Policy Brief, March 2025
³ Kaiser Family Foundation, Medicaid Enrollment Tracker, April 2025
⁴ Amivie Health, Testimony to House Budget Committee, June 2025

Tim Rowan is a 30-year home care technology consultant who co-founded and served as Editor and principal writer of this publication for 25 years. He continues to occasionally contribute news and analysis articles under The Rowan Report’s new ownership. He also continues to work part-time as a Home Care recruiting and retention consultant. More information: RowanResources.com
Tim@RowanResources.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