The Home Care Association of Florida (HCAF) submitted comments to the Centers for Medicare & Medicaid Services (CMS) today regarding the proposed Calendar Year (CY) 2027 Home Health Prospective Payment System (HH PPS) rule. 

The proposed rule includes a 2.1% annual payment update, changes to outlier payments, a 3.0% temporary behavioral adjustment, significant provider enrollment provisions, and proposals involving palliative care and quality reporting.

HCAF welcomed several parts of the proposal, including the payment update, the decision not to impose another permanent behavioral adjustment, improvements to the outlier policy, and CMS’s recognition that palliative care may be furnished through the Medicare home health benefit.

However, HCAF warned that those improvements would not offset the proposal’s potential effects on Florida providers and patients.

HCAF thanks the members who shared operational data and firsthand perspectives, helping ensure that our comments reflect the real-world challenges facing Florida’s home health providers and patients.

Payment and Access

HCAF urged CMS not to finalize the 3.0% temporary payment reduction, arguing that compliant providers should not bear additional nationwide cuts based on calculations that may be distorted by fraudulent or anomalous utilization.

Although CMS estimates that the proposal would increase aggregate home health payments nationally by 2.4%, HCAF emphasized that the figure does not represent the experience of every agency. Florida providers could face substantial losses because of wage index changes and other payment factors.

HCAF’s analysis found that 22 of Florida’s 25 urban labor markets would receive a lower wage index in 2027, while the statewide rural index would also decline. The association asked CMS to retain the permanent 5.0% wage index cap, provide transition protection, publish provider- and county-level impact information, and monitor access indicators such as referral acceptance, start-of-care delays, agency closures, and hospital discharge delays.

Targeted Program Integrity Enforcement

HCAF strongly supports removing fraudulent and unsafe providers from Medicare but raised concerns about proposals that could allow retroactive revocations or sanctions based primarily on geography, office location, business relationships, or administrative errors.

The association urged CMS to require provider-specific evidence, materiality, intent, written findings, due process, and proportionate remedies. HCAF also asked CMS to preserve the existing 60-day period for submitting claims following a revocation and to allow corrective action for good faith administrative and reporting errors.

A Better Home Health Wage Index

HCAF supports exploring a home health agency-specific wage index because the hospital wage index does not adequately reflect home health labor costs. However, the association cautioned against adopting an untested methodology.

Any new index should account for the occupations furnishing home health care, travel time, mileage, contract labor, rural competition for workers, interpreter needs, emergency preparedness, and Florida’s unique disaster response responsibilities. HCAF also recommended transparent modeling, reliable data, a permanent cap, and a multi-year transition.

Palliative Care and Quality Reporting

HCAF supports clearer recognition of palliative care under the Medicare home health benefit. The association asked CMS to provide practical coverage examples, clarify homebound eligibility, protect hospice choice, and ensure that agencies are appropriately paid for advance care planning and related clinical work.

HCAF also recommended excluding palliative periods from the Home Health Value-Based Purchasing (HHVBP) Model until suitable measures and risk adjustment are developed.

For quality reporting, HCAF urged CMS to preserve relief for hurricanes, system outages, cyber incidents, and other extraordinary circumstances. Providers should also receive notices through multiple channels rather than relying solely on a data submission portal.

HCAF’s message to CMS is straightforward: Medicare can strengthen program integrity without weakening the legitimate providers that keep beneficiaries safely at home. The final rule should target demonstrated misconduct while protecting access, workforce stability, emergency readiness, and the financial capacity necessary to deliver high-quality home health care throughout Florida.