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CMS 2027 Proposed Rule Explained: What the 2.4% Increase Actually Means


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CMS just proposed a 2.4% payment increase for home health in 2027. If that's the only number you take away, you're missing a lot.

Tom Maxwell sits down with Jay Duty, COO at Maxwell TEC, to unpack what's actually happening underneath the headline: a temporary rate cut, a nearly $5 billion recoupment, a full case-mix recalibration, and provider enrollment changes that could put your Medicare billing privileges at risk.

Jay spent his first ten years in the hospital business at HCA before moving into post-acute care strategy, eventually landing at Maxwell TEC. In this conversation, he and Tom walk through what CFOs need to know before they finalize next year's budget, why the "behavioral adjustment" methodology has the industry pushing back, and what a home health specific wage index could mean for high-cost and rural markets.


Topics Include:

  • The real math behind the 2.4% headline number and where it actually comes from
  • Why the temporary 3% clawback matters more than the payment increase
  • How to model your 2027 budget before the final rule drops in November
  • The CMS wage index proposal and its impact on rural and high-cost markets
  • What CMS's expanded provider enrollment authority means for your Medicare billing risk


The comment period for this rule runs through August 31, 2026. If you're a home health agency owner, operator, or CFO, this episode gives you the framework to build your comment letter and your budget at the same time.


Connect with Jay Duty:


Chapters:

  • 0:00 Intro: the 2.4% headline everyone's getting wrong
  • 1:26 Jay Duty's path from HCA to home health strategy
  • 1:53 The first thing Jay checks in a new CMS rule
  • 2:21 What's actually driving the 2.4% number
  • 3:55 The one sentence every CFO needs to remember
  • 4:49 The behavioral adjustment, explained
  • 6:26 Real example: therapy-only cases and the 30-day billing trap
  • 7:44 The $4.9 billion recoupment breakdown
  • 9:54 Is CMS's data methodology actually flawed?
  • 12:15 What a strong industry comment letter argues
  • 13:33 Why this rule always lands mid-budget cycle
  • 14:46 How to model your 2027 budget starting now
  • 17:01 Why visits per period keep falling
  • 19:45 What investors and lenders should hear from you now
  • 21:28 The case for a home health specific wage index
  • 24:00 CMS's expanded power to deny or revoke enrollment
  • 25:34 Can industry comments actually move the needle?
  • 28:16 What makes a comment letter valuable to CMS
  • 29:48 Will this adjustment mechanism still exist in five years?
  • 31:51 What to do this week if you run an agency
  • 33:08 How to reach Jay Duty


Sponsors:

  • Maxwell TEC: https://www.maxwelltec.com
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Last Visit FirstBy Tom Maxwell