HCANYS Memo on CY2026 HHPPS Proposed Rules for Medicare Home Health Services
The Situation Report | July 21, 2025
The U.S. Centers for Medicare and Medicaid Services (CMS) has posted for public inspection its Calendar year (CY) 2026 proposed Home Health Prospective Payment System (HHPPS) rule for Medicare home health services.
The proposed rule can currently be read here.
The Proposed Rule presents serious concerns for the home health community as CMS proposes further significant rate reductions to account for the change to the Patient Driven Groupings Model (PDGM) payment model in 2020. Since the inception of the PDGM, total Medicare home health expenditures have declined year-over-year, a fact that is directly at odds with CMS’ assertion that aggregate expenditures under the new system are higher than they otherwise would have been prior to the 2020 changes. However, Medicare law requires CMS to make permanent and temporary adjustments intended to ensure that the transition to the PDGM payment model is budget neutral in comparison to expected Medicare spending on the 2019 payment model.
All told, taking into account the various adjustments to the base episodic rate, CMS estimates the CY 2026 proposed rule will decrease Medicare home health expenditures by 6.4% or $1.135 Billion nationally when all the adjustments are applied.
HCANYS is very concerned with the CMS’ proposed rule. The stability of home health care is at risk because of CMS proposing the application of a flawed methodology for assessing whether the PDGM payment model led to budget neutral spending in 2020 and later years.
With significantly rising costs for staff, training and more, home health agencies cannot withstand the impact of the proposed rate cut.
HCANYS will exercise strong advocacy to protect the Medicare home health benefit including immediate engagement with New York’s Congressional delegation in July as well as working with our colleagues at the National Association for Home Care and Hospice (NAHC).
HCANYS' detailed memo on the rule can be found here, and the Association will submit comments that are due to CMS by August 29.
HCANYS will share with the membership our comments to CMS shortly after they are submitted. HCANYS expects CMS to post the CY 2026 home health final rule towards the end of October. HCANYS will provide the membership with a follow-up Public Policy Memorandum when this occurs.
For further information on CMS’s CY 2026 HHPPS proposed rule, contact Patrick Conole at (518) 810-0661 or