HCAF has submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) on the Calendar Year (CY) 2026 Home Health Prospective Payment System (HHPPS) proposed rule, which closed for public comment on Friday, August 29, 2025. A final rule is expected around Halloween.

• Related: CMS Faces Flood Of Comments Opposing 2026 Home Health Payment Rule (Home Health Care News, 8/27/25)

As the unified voice of Florida’s home health provider community, HCAF not only filed detailed comments reflecting member feedback, but also mobilized providers statewide through our Legislative Action Center. Using customizable templates, members were able to share their unique perspectives — highlighting how the proposed cuts would affect patients, payments, workforce stability, and day-to-day operations. Together, this effort amplified the voice of Florida home health agencies and underscored the urgency of the issue.

Key Concerns

CMS has proposed payment adjustments amounting to a 9% gross cut before inflation — the largest single-year reduction since the Patient-Driven Groupings Model (PDGM) took effect in 2020. While CMS frames the rule as a 6.4% net decrease, the agency continues to rely on behavioral assumptions rather than actual claims data, directly contradicting the Bipartisan Budget Act of 2018.

In our comments, HCAF emphasized several critical concerns:

• Florida’s heightened vulnerability: The state has seen 144 home health agency closures in the past year, leaving older adults in rural and underserved areas at risk of losing access to care.
• Workforce crisis: Florida ranks last in the nation for home health aide availability, with reimbursement rates too low to recruit and retain staff. Demand for home health nurses is projected to grow nearly 50% by 2035, yet CMS continues to cut funding.
• Flawed policy design: Persistent errors in CMS’s modeling, inaccurate market basket forecasts, and changes to the outlier formula make it even harder to serve complex, high-need patients.

Support for Targeted Reforms

While strongly opposing the payment cuts, HCAF expressed support for CMS’s proposal to expand practitioner eligibility for face-to-face encounters, which would improve access in rural areas by reducing delays.

We also urged CMS to phase in quality reporting and value-based purchasing requirements only after validating fairness and feasibility, warning that premature implementation could penalize providers caring for the most vulnerable patients.

HCAF’s Recommendations to CMS

In our comments, HCAF urged CMS to:

• Withdraw the proposed 9% cut.
• Base future adjustments on real-world provider data, not assumptions.
• Correct past market basket forecast errors.
• Support workforce growth by aligning reimbursement with competitive wages.
• Eliminate retroactive “clawbacks” that unfairly penalize current providers for fraudulent claims from closed agencies.

What’s Next

CMS is expected to finalize the CY 2026 rule in late October, with changes taking effect January 1, 2026. HCAF will remain at the forefront — working with national partners, lawmakers, and state leaders — to ensure Florida’s providers are heard and that patient access to home-based care is protected.

Click here to read HCAF’s official comments to CMS on the proposed rule.