August 28, 2025 Washington, DC – In comments submitted to the Centers for Medicare and Medicaid Services (CMS) responding the CY2026 Home Health Proposed Payment Rule, LeadingAge, the association of nonprofit and mission-driven providers of aging services, including home health agencies, expressed grave concerns over the impact of the deep reductions in Medicare fee for service (FFS) payment rates the agency put forth in its rule–including reduced access to home health care. In addition to urging CMS to halt the devastating 9 percent payment cuts, LeadingAge also expressed the urgent need to correct flawed methodologies in the budget neutrality adjustments, and to address structural issues in the Home Health Value-based Purchasing (HHVBP) program to protect beneficiaries–many of whom have complex needs–and the providers who deliver care:

“Home health care is a vital part of the aging services ecosystem. Yet access to these services is rapidly declining: fewer beneficiaries are receiving care, agencies are closing, and as a result, hospitals face growing discharge delays. These disruptions increase emergency department visits, readmissions, mortality, and overall health care spending,” said Katie Smith Sloan, president and CEO, LeadingAge. “CMS’ payment proposal creates fresh challenges for all agencies–but poses a particular threat to nonprofits, who, as safety net providers, serve a significant portion of older adults with complex care needs and who also deliver essential services like vaccination programs and maternity visits. We urge CMS to take immediate action to preserve access to home health and protect the providers–including the many nonprofits–that will be disproportionately impacted by these cuts.

In addition to serving patients with more complex care needs, nonprofit home health agencies tend to be smaller and operate with thinner margins. They reinvest any surplus revenue into their communities. Since CY2023, CMS has imposed an 8.8% cut to Medicare FFS rates, and the proposed CY2026 rule adds another 9% reduction—an unprecedented blow that could be a death knell for mission-driven providers. These cuts will further erode the ability of nonprofit agencies to serve as safety net partners, accept complex referrals, and maintain essential services like vaccination programs and maternity visits.

We call on CMS to reject the proposed permanent and temporary budget neutrality adjustments for CY2026 and to correct flaws in the payment methodology. These include addressing forecasting errors, incorporating Hierarchical Condition Categories (HCC) scores to reflect patient acuity, investigating potential fraud in Los Angeles, and revising how claims and behavioral assumptions are calculated. Without these changes, the payment system will continue to destabilize the sector and threaten the sustainability of nonprofit agencies already operating under tight margins.”

Additionally, in our comments we urge CMS to address the following concerns by taking specific actions:

• Pause all updates to the HHVBP program until structural flaws are resolved.
• Exclude HHVBP participating agencies that fail to meet quality reporting requirements from payment adjustments.
• Redesign cohort distributions based on average daily census or the Outcome and Assessment Information Set (OASIS) episodes during the baseline year.
• Add risk adjustments for patients unlikely to show functional improvement, as supported by the Jimmo v. Sebelius settlement.
• Implement an efficient reactivation process for providers whose order, certifying, and referring privileges are deactivated, to prevent care delays.