The Home Care Association of Florida (HCAF) has submitted formal comments to the Florida Agency for Health Care Administration (AHCA) on proposed revisions to Rule 59A-8.0248, Florida Administrative Code, governing the state’s Excellence in Home Health Award program.

The comments reflect extensive feedback received from HCAF members representing both skilled and non-skilled home health providers across Florida and build upon the Association’s successful advocacy during the 2025 Legislative Session, when House Bill 1353 directed AHCA to modernize the award program.

The legislation — championed by HCAF and signed into law by Governor Ron DeSantis — was intended to create a more practical, inclusive recognition program after the original framework failed to produce a single award recipient since its inception.

“HCAF appreciates AHCA’s efforts to implement the Legislature’s reforms and modernize the Excellence in Home Health Award program,” said Denise Bellville, RN, BS, Executive Director of HCAF. “Overall, we support the direction of the proposed rule while offering recommendations that we believe will make the program more transparent, practical, and achievable for agencies of all sizes and service models.”

Key Recommendations

Drawing on member input, HCAF’s comments encourage AHCA to further strengthen the proposed rule by:

• Clarifying “evidence-based practices.” HCAF recommends providing flexibility in how agencies demonstrate compliance, including through existing quality assurance activities, accreditation standards, policies and procedures, staff training, and other documented quality improvement initiatives.
• Reducing unnecessary administrative burden for skilled providers. Rather than requiring detailed written summaries of adverse events, HCAF recommends allowing agencies to submit aggregate quality assurance data and documentation of corrective actions that better reflect ongoing performance improvement efforts.
• Refining quality measures for non-skilled agencies. While strongly supporting the creation of separate criteria for non-skilled providers, HCAF recommends replacing subjective emotional wellness requirements with broader, more measurable standards focused on client well-being, independence, quality of life, and person-centered care.
• Providing flexibility for employee satisfaction measures. HCAF supports the proposed workforce stability standards and recommends allowing agencies to use a variety of documented methods — including surveys, interviews, and employee feedback programs — to demonstrate workforce engagement.
• Broadening the definition of innovation. HCAF encourages AHCA to clarify that innovation extends beyond advanced technologies such as artificial intelligence and robotics to include workforce development, caregiver training, community partnerships, scheduling improvements, communication enhancements, and other operational innovations accessible to agencies of all sizes.
• Increasing transparency surrounding the new inspection scoring methodology. Because eligibility for the award will depend on achieving a Service Excellence Inspection Score of 50 points or less, HCAF recommends that AHCA publish the complete methodology and provide stakeholders an opportunity to review and comment before the rule is finalized.
• Leveraging existing operational data. To encourage participation, HCAF recommends minimizing new reporting requirements by relying, whenever possible, on information agencies already collect through quality assurance programs, accreditation activities, workforce monitoring, and satisfaction initiatives.

Supporting a More Meaningful Recognition Program

HCAF noted that the proposed rule represents a significant improvement over the previous award framework, which relied heavily on clinical outcome measures and percentile-based rankings that were not applicable to many providers — particularly agencies providing only non-skilled services.

The Association’s comments emphasize that the long-term success of the Excellence in Home Health Award program will depend on creating standards that are rigorous while remaining transparent, operationally practical, and attainable for high-performing providers across Florida’s diverse home health industry.

HCAF thanks AHCA for its collaborative approach throughout the rulemaking process and looks forward to continuing to work with the agency to ensure the revised award program fulfills its intended purpose of recognizing and promoting excellence in home health care throughout Florida.