Last week, the Continuing Appropriation and Extensions Act of 2026 was signed, and we’re going to examine how this legislation directly affects home health and hospices agencies.
For many agencies, the most significant news is that telehealth face-to-face encounters have now been extended through January 30, 2026. Although it appeared there would be a gap in coverage between October 1 and the passage of this legislation, the new legislation removes the previous September 30 deadline and extended it to January 30, 2026.
Any face-to-face encounter completed via telehealth between October 1 and the date the bill was signed will still be considered valid.
Even now, in mid-to-late November, when admitting new patients to home health, you may use a face-to-face encounter completed within the previous 90 days as long as it meets all required criteria. If that encounter was conducted via telehealth during October, it can still be accepted.
Hospice is a bit more complicated since face-to-face encounters for recertifications can be completed up to 30 days before the new period begins, which may place them in October. If those encounters were conducted via telehealth, they will still be acceptable.
Please ensure that documentation from the practitioner conducting the encounter validates that any telehealth face-to-face encounter, whether for home health or hospice, was performed using both audio and video, not audio only. You must also verify that the telehealth platform used for the encounter is HIPAA-compliant.
Another point related to the government reopening is that TRICARE payments, which had stopped during October, have now resumed. All services provided during the shutdown period will be paid retroactively.
Lastly, the PAYGO provision introduced in 2010, which would have added an additional 4% to sequestration, has been waived under this legislation. As a result, that extra 4% will not be applied to sequestration at this time.
HPS is waiting anxiously for the Final Rule to be released for 2026 implementation, and we will share an update as soon as it is released. For any question you may have, please feel free to reach out to us.
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