In comments submitted August 28, 2025 to the Centers for Medicare and Medicaid Services (CMS) responding the CY2026 Home Health Proposed Payment Rule, LeadingAge urges the agency to halt the devastating 9 percent payment cuts and 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