CMS is proposing deep payment cuts for home health providers in 2026, with an overall payment cut of 6.4%, including a 4.6% temporary payment adjustment to chip away at billions of dollars CMS claims it has overpaid for home health services in the first few years under PDGM.  
 
The 2026 Home Health Prospective Payment System proposed rule, released late Monday, June 30, 2025, also includes several changes to quality reporting and Home Health Value-Based Purchasing (HHVBP) measures.  
 
The rule includes an update to the face-to-face encounter requirements that had been telegraphed by notices from Medicare Administrative Contractors in recent weeks. There are also requests for information on future quality measures around Trump administration priorities, including nutrition and well-being. 
 
Payment update 
 
CMS estimates that the 2026 home health payments will decrease in the aggregate by 6.4%, or a $1.1 billion reduction compared to 2025.
  
The reduction in payments includes a permanent 3.7% cut in the national, standardized 30-day period payments as part of behavioral adjustments under PDGM, amounting to a $655 million decrease. It is offset partially by a 2.4% increase in the home health payment update percentage. If finalized as proposed, the 4.6% temporary payment adjustment will mean an $815 million decrease in payments. CMS notes future temporary adjustments will be determined as needed.  
 
HHCAHPS update  
 
If finalized, agencies will be getting a revised and shortened HHCAHPS survey beginning in April 2026. The shorter survey has been a demand from the industry for several years and follows the recent implementation of an updated CAHPS Hospice survey.  
 
The proposed updates to the survey include three new questions:  
  • Whether the care provided helped the patient take care of their health. 
  • Whether the patient’s family/friends were given sufficient information and instructions. 
  • Whether the patient felt the staff cared about them “as a person.” 
Several questions would be removed, including four related to medication management, three related to the type of staff that served the patient and one on whether the patient received information about the services they would get when they started care. 
 
Face-to-face encounters 
 
The proposed rule would allow different community providers to complete the face-to-face encounter and certify the patient for home health. In the past, the same community practitioner was expected to conduct the face-to-face and certify the patient — and this has frequently come up in claim denials under medical review. 
 
As explained in guidance from the MACs, CMS will allow a different practitioner to conduct the face-to-face encounter if there is a clear relationship between the two providers prior to the certification. For example, the two providers are in the same practice. 
 
HHVBP and other proposed changes 
  • Add 3 HHVBP measures. The changes to the HHCAHPS will mean the removal of three measures used to determine payment adjustments under HHVBP. CMS is also proposing that it will add three OASIS-based measures to the HHVBP model related to bathing and dressing, as well as a claims-based measure related to Medicare spending per beneficiary. 
  • Delete COVID vaccine question. CMS is proposing to remove the OASIS item that asks if the patient is up to date on the COVID-19 vaccine — not surprising considering the administration’s posture on vaccines.  
  • Remove four items related to Social Determinants of Health (SDoH) involving living situation, food security and utilities. Finalized in the 2025 rule, these items were expected to be added to the OASIS in a future update.  
  • Revise reconsideration policy. The update would allow providers to submit a request for reconsideration of an initial determination of noncompliance with quality-reporting requirements if they can demonstrate compliance.  
  • Clarify all-payor OASIS data. Finally, CMS proposes updates to the regulatory text to account for all-payor submission of OASIS data.  
Requests for information 
 
CMS is seeking information on: 
  • A change to the final data submission deadline period from 4.5 months to 45 days. 
  • The digital quality measurement (dQM) transition for HHAs and the adoption of health information technology (IT), and standards including Fast Healthcare Interoperability Resources (FHIR).  
  • Possible future quality reporting measure concepts of interoperability, cognitive function, nutrition and patient well-being. 
The proposed rule is scheduled to be published Wednesday, July 2, 2025.  
   
You can access an early release of the 591-page rule at https://public-inspection.federalregister.gov/2025-12347.pdf.