The Home Care Association of Florida (HCAF) has submitted formal comments — reflecting input from its members — to the Agency for Health Care Administration (AHCA) on proposed changes to Rule 59A-8.0248: Excellence in Home Health Program following last week’s rulemaking workshop. Representing more than 2,300 licensed home health agencies statewide, HCAF emphasized that the program’s criteria must be meaningful, fair, and achievable for both skilled and non-skilled providers.

In its recommendations, HCAF urged AHCA to prioritize measurable outcomes such as reducing hospitalizations, preventing adverse events, and improving patient satisfaction, while ensuring private-pay agencies without federal ratings can demonstrate quality through alternative measures such as accreditation survey results or compliance history. For non-skilled agencies, HCAF recommended criteria focused on caregiver continuity, fall prevention, reduced emergency room visits, and operational excellence.

HCAF also highlighted cross-cutting priorities that apply to all provider types, including workforce stability, patient and client satisfaction, and a broad definition of innovation that recognizes both advanced technologies like telehealth and modest but impactful tools such as electronic medical records or caregiver apps. In addition, HCAF urged AHCA to leverage existing data sources, such as the Direct Care Workforce Survey collected at license renewal, to minimize reporting burdens on providers.

“Since the program’s implementation in 2023, no provider has earned the designation,” wrote Denise Bellville, RN, Executive Director of HCAF. “This demonstrates that the criteria, as originally structured, were not workable or achievable.”

HCAF noted it stands ready to collaborate with AHCA throughout the rulemaking process and to convene providers statewide to ensure broad input.

Click here to read HCAF’s full comments.