MassHealth Regulatory Update

Alliance Testifies on MassHealth Home Health and Hospice Proposals

At public hearings on proposed changes to home health and hospice regulations, the Home Care Alliance of Massachusetts urged the state to pair its value-based care goals with greater clarity, policy alignment, and sustainable funding.

The Alliance said the direction of the proposal is important, but warned that implementation details, flat reimbursement, and expanding compliance expectations could create new strain for providers already operating under workforce and cost pressures.

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

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. Their testimony reflected both support for the state’s broader direction toward value-based care and concern that key provisions require further definition before the model can succeed in practice.

Questions remain about the proposed VBP model

A central feature of the proposal is a new value-based payment model that would apply to a defined population of higher-acuity patients and introduce performance-based payment adjustments.

The Alliance said more detail is needed on how quality measures will be defined, how provider performance will be evaluated, and how outcomes will be interpreted when factors outside an agency’s control may affect results.

State officials described the proposal as an effort to modernize care delivery, improve coordination, and better align services with patient needs while maintaining fiscal stability. The Alliance agreed with those goals, but emphasized that the effectiveness of the model will depend on how clearly those expectations are translated into day-to-day operations.

Operational and clinical questions need clarification

In addition to the VBP proposal, the Alliance raised concerns about several regulatory changes that could affect day-to-day clinical practice.

Those include revisions to the definition of medication administration visits, where the proposed change from “sole” to “primary” purpose may introduce ambiguity around documentation expectations and visit scope. The Alliance requested clarification so providers can apply the rule consistently in clinical settings.

The Alliance also noted that proposed updates to face-to-face encounter requirements may not fully align with recent federal Medicare changes. That mismatch, if not resolved, could create confusion for agencies trying to comply with both state and federal requirements at the same time.

Providers are already operating under strain

According to Alliance testimony, home health providers are already facing a difficult environment. Referral demand continues to increase, while workforce shortages limit the ability of agencies to accept new patients. At the same time, inflation, wage growth, technology costs, and compliance obligations continue to raise the cost of delivering care.

The Alliance argued that maintaining current reimbursement rates while layering on a new payment structure and expanded administrative expectations would represent a meaningful shift for providers already managing workforce instability and rising patient complexity.

That concern extends beyond agency finances. The Alliance emphasized that home health remains a critical part of the broader healthcare system, supporting hospital discharge, reducing institutional care, and providing a lower-cost setting for patients with complex needs.

What comes next

The Alliance’s testimony was informed by feedback from more than 80 providers who participated in a member briefing earlier this week. That provider input helped shape the concerns raised during the hearing, particularly around implementation, reimbursement, and regulatory consistency.

As MassHealth moves toward finalizing the regulation, the outcome will play an important role in shaping the future of care delivery in the home. For providers, the issue is not whether change is coming. It is whether that change is structured in a way that supports access, workforce stability, and practical implementation across the field.