The CY 2026 HH PPS Proposed Rule includes a range of regulatory and quality reporting updates that home health providers should carefully review. While much of the national attention has focused on reimbursement changes, these non-financial proposals will impact operations, compliance, and quality strategies across the industry. The Home Care Alliance of Massachusetts has reviewed the proposed updates and highlights the following key areas for member awareness and comment.

Expanded Face-to-Face Encounter Rules – A Win for Agencies!

CMS proposes to allow any community physician, nurse practitioner (NP), clinical nurse specialist (CNS), or physician assistant (PA) to complete the required face-to-face encounter—even if they are not the certifying or discharging practitioner. This change aligns the regulations with the CARES Act and is a welcome simplification for agencies managing referrals from varied sources.

What it means: Agencies will have greater flexibility. The FTF provider no longer needs to match the ordering provider. This will reduce delays and administrative headaches—especially in community-based referrals.

OASIS Data Changes – SDOH at Risk

CMS proposes the removal of the COVID-19 vaccine OASIS item as well as four Social Determinants of Health (SDOH) items: Living Situation, Food Security (2 items), and Utility Access.

What it means: While the removal of the COVID-19 vaccination item may be timely and appropriate, the removal of the SDOH data elements could be concerning. These data points help identify patient barriers and are essential for meaningful risk adjustment and health equity.

The Home Care Alliance will provide input to CMS on the potential retention or replacement of Social Determinants of Health (SDOH) measures in future reporting requirements. We encourage members to submit comments emphasizing the importance of capturing social risks to ensure a level playing field across providers.

Streamlined HHCAHPS Survey Coming in 2026

CMS will implement a revised, simplified version of the Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) survey beginning in April 2026.

What it means: The streamlined format is designed to reduce burden on patients and caregivers, improve response rates, and enhance the reliability of patient experience data. This change may also positively impact HHVBP scoring and reporting.

Expanded HHVBP Model – Measure Set Changes & Request for Input

Beginning in April 2026, CMS proposes changes to the HHCAHPS survey that would affect the scoring of three current measures in the expanded HHVBP model. As a result, CMS proposes to remove the following measures from the HHVBP applicable measure set:

• • Care of Patients
• • Communication Between Providers and Patients
• • Specific Care Issues

CMS also proposes adding four new measures: three OASIS-based measures related to bathing and dressing, and one claims-based measure—Medicare Spending per Beneficiary for the Post-Acute Care (PAC) setting.

To reflect these changes, CMS proposes to adjust the weighting of measures and categories and to add a new removal criterion (Factor 9), allowing removal if a measure is not feasible to implement.

Additionally, CMS seeks input on future HHVBP changes, including a respecified Falls with Major Injury measure and possible changes to HHCAHPS scoring rules and applicability.

Strengthening Medicare Provider Enrollment Oversight

To address fraud and ensure program integrity, CMS proposes expanding its authority to retroactively revoke provider enrollment to the date noncompliance began. This would enable CMS to recover payments made to noncompliant providers.

CMS also proposes two new triggers for revocation or deactivation:

• • When beneficiaries attest that services were not furnished as claimed
• • When a physician or practitioner has not ordered or certified any services for 12 months

CMS Requests Input on Well-being and Regulatory Burden

CMS issued two Requests for Information (RFIs) in the proposed rule:

1. Well-being and Nutrition: Feedback is requested on measures of life satisfaction, emotional well-being, social connection, purpose, and healthy lifestyle behaviors.
2. Regulatory Streamlining: Stakeholders are encouraged to propose ways to simplify Medicare regulations and reduce administrative burden. Submit comments at: https://www.cms.gov/medicare-regulatory-relief-rf