HCAF Joins National Alliance and 60+ State Associations to Oppose CMS’s Proposed 9% Medicare Home Health Cut

HCAF Joins National Alliance and 60+ State Associations to Oppose CMS’s Proposed 9% Medicare Home Health Cut
HCAF has joined more than 60 state and national organizations in co-signing a pre-comment letter to Dr. Mehmet Oz, Administrator of the Centers for Medicare & Medicaid Services (CMS), regarding the Calendar Year (CY) 2026 Home Health Prospective Payment System (HHPPS) Proposed Rule.
Coordinated by the National Alliance for Care at Home, the letter urges CMS to withdraw the proposed 9% cut to Medicare home health payment rates, citing major concerns over the impact on patient access, agency sustainability, and workforce capacity. This proposed cut would reduce payments by an estimated $1.13 billion compared to CY 2025 — on top of nearly 9% in cumulative cuts implemented between CY 2023 and CY 2025.
The joint letter outlines several core concerns:
- Access to Care at Risk: More than 1,000 home health agencies have closed since 2020, and CMS’s own data show that nearly one-third of hospital-referred patients never receive home health services — often due to capacity and workforce shortages. Continued cuts will only worsen this trend, especially in rural and underserved areas.
- Flawed Methodology: The proposed cuts are based on simulations that rely on flawed comparisons between the current PDGM payment model and the pre-2020 system. CMS’s assumptions do not accurately reflect actual provider behavior or spending patterns, leading to unjustified reductions.
- Workforce Instability: As the demand for home health grows, payment reductions threaten to further destabilize the workforce by limiting agencies’ ability to recruit and retain nurses, aides, and therapists.
- Failure to Address Fraud Directly: Instead of targeting fraudulent providers, CMS is using systemwide payment reductions — based in part on data from bad actors — as a blunt tool, penalizing legitimate providers and undermining care for vulnerable patients.
- Violation of Congressional Intent: The letter argues that CMS’s approach contradicts the original legislative intent of budget neutrality under PDGM and effectively rebases payment rates in a manner Congress never authorized.
As Florida’s leading voice for home care providers, HCAF strongly opposes the proposed cuts and is working closely with national partners to protect access to care and promote fair, sustainable payment policies. We will continue to advocate on behalf of our members and the patients they serve throughout the formal comment period and beyond.
We thank the National Alliance for Care at Home for leading this effort and uniting the provider community in a unified response. The final comment letter will be submitted before the official CMS deadline, and we encourage all HCAF members to submit individual comments as well.
Stay tuned for tools and templates to support your participation in the comment process.
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