A massive regulatory overhaul looms on the horizon for home health agencies. The proposed Calendar Year 2026 Home Health Payment Update rule spans nearly 600 pages, packed with changes that extend far beyond payment adjustments.

• Proposed expansion of face-to-face encounter policy to allow not just physicians but also NPs, CNSs, and PAs to perform encounters regardless of prior patient relationship
• CMS plans to remove COVID-19 vaccine reporting measure and four social determinants of health assessment items from OASIS data collection
• Proposed shorter HHCAHPS survey implementation beginning April 2026 with fewer questions
• Potential reduction in data submission timeframes from 4.5 months to 45 days to improve measure timeliness
• Updates to Home Health Value-Based Purchasing including measurement changes and reweighting of components
• Technical updates to Conditions of Participation text to accommodate all-payer OASIS data submission
• Multiple requests for information on interoperability, wellness measures, and falls reporting

Comments on these proposed changes must be submitted to CMS by August 29th. The final rule is expected to be published in late October or early November.

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