Today, MassHealth held public hearings on proposed updates to home health and hospice regulations, outlining changes aimed at strengthening care delivery in home and community-based settings.

The proposed VBP model would apply to a defined population of higher-acuity patients and introduce new performance-based payment adjustments. The Alliance raised questions about how quality measures will be defined and how providers will be evaluated, particularly given factors outside of provider control.

In addition to the VBP model, the Alliance provided comments on several proposed regulatory changes that may impact day-to-day clinical practice. These include revisions to the definition of medication administration visits (MAV), where the shift from “sole” to “primary” purpose may introduce ambiguity around documentation and visit scope. The Alliance requested clarification to support consistent clinical expectations across providers.

Representing the Home Care Alliance of Massachusetts, CEO Jake Krilovich and Director of Regulatory & Clinical Affairs Colleen Pierro testified on behalf of more than 200 providers across the Commonwealth.

The Alliance expressed support for the state’s direction toward value-based care, while emphasizing that key elements of the proposal require further definition to ensure successful implementation.

At the same time, the proposal would maintain current reimbursement rates for home health services, even as providers continue to face rising labor, technology, and operational costs.

The Alliance noted that the shift to a new payment structure—combined with expanded administrative and compliance requirements—represents a meaningful change for providers already managing workforce constraints and increasing patient complexity.

Pierro focused on the operational realities of implementing the proposal, noting that providers will need clear guidance on eligibility, performance measurement, and care delivery expectations under the new model.

The Alliance also noted that proposed updates to face-to-face (F2F) encounter requirements may not fully align with recent federal Medicare changes. Ensuring consistency between state and federal policy will be important to avoid confusion for providers and support efficient care delivery.

According to Alliance testimony, home health providers are already operating under strain. Referral demand continues to increase, while workforce shortages limit the ability of agencies to accept new patients. At the same time, inflation and wage growth have increased the cost of delivering care.

The proposed VBP model would apply to a defined population of higher-acuity patients and introduce new performance-based payment adjustments. The Alliance raised questions about how quality measures will be defined and how providers will be evaluated, particularly given factors outside of provider control.

State officials noted that the proposal is intended to modernize care delivery, improve coordination, and better align services with patient needs, while maintaining fiscal stability.

The Alliance emphasized that home health care remains a critical component of the healthcare system—supporting hospital discharge, reducing institutional care, and serving as a lower-cost alternative for patients with complex needs.

The Alliance’s testimony was informed by feedback from more than 80 providers who participated in a member briefing earlier this week.

As the state moves toward finalizing the regulation, stakeholders on all sides agree that the outcome will play a significant role in shaping the future of care delivery in the home.