On February 27, 2026, the Home Care Association of Florida (HCAF) formally submitted comments to the Florida Agency for Health Care Administration (AHCA) regarding proposed revisions to Rule 59G-4.261, Florida Administrative Code, incorporating the February 2026 draft of the Private Duty Nursing and Family Home Health Aide Services Coverage Policy.

These proposed rule changes are intended to implement statutory reforms enacted during the 2025 Florida Legislative Session under SB 1156, which updated training, utilization, and oversight standards for the Home Health Aide for Medically Fragile Children (Family Home Health Aide) program and directed AHCA to revise Medicaid coverage policy accordingly.

HCAF’s comments reflect extensive feedback from home health agencies serving medically fragile children and other vulnerable Medicaid recipients who depend on these in-home services. While clarifying statutory changes is appropriate, members identified several areas where draft language may unintentionally create access barriers, increase administrative burden, or introduce operational challenges.

Summary of Key Issues Raised by HCAF

HCAF’s member-driven feedback focused on the following issues:

• Eligibility Clarifications – Ensuring revised language is not interpreted by managed care plans in a way that narrows coverage or creates new authorization barriers.
• Independent Nurse Participation – Seeking clarity on supervision requirements and avoiding unintended access limitations, particularly in rural and underserved areas.
• Duplication of Services and Hospital Transitions – Requesting clarification to prevent nonpayment for medically necessary services provided prior to hospital admission or following same-day discharge.
• Oversight Under the Related-Provider Model – Urging AHCA to define “oversight” in objective, measurable terms to prevent inconsistent or heightened supervisory expectations.
• Documentation Standards – Clarifying that references to federal regulatory standards do not impose Medicare certification requirements for Medicaid participation.
• Multi-Recipient Rate Adjustments – Seeking clarification to ensure each recipient receives full reimbursement for fully authorized services, regardless of shared dwelling arrangements.

Moving Forward

HCAF’s submission was shaped by the thoughtful, practical input of providers statewide. We thank our members who shared real-world operational insight and examples that informed these comments.

HCAF will continue to monitor the rulemaking process closely and advocate to ensure the final policy:

• Protects access to care for medically fragile children
• Aligns with statutory intent
• Remains operationally feasible
• Supports a stable and sustainable provider network

Members will be kept informed of developments as the rule progresses.