The newly released 2026 proposed rule for home health brings significant implications for our industry, below are key takeaways and guidance to help you craft impactful comments during the open comment period.
It’s been a pleasure connecting with many of you at your state association meetings this spring and summer, as well as at the recent National Financial Summit. There is serious concern that, if finalized, this proposed rule could have a profoundly negative impact on home health agencies nationwide, no matter the size of the organization.
It is critically important for individual agencies to submit comments on the proposed rule and share their specific concerns. While feedback from state associations and national organizations is anticipated, policymakers also need to hear directly from providers on the front lines, especially regarding how the proposed changes could impact day-to-day operations and, most importantly, patient access to care.
We’ve heard from home health agencies that have already had to limit how far their clinicians can travel to reach patients, resulting in some individuals in outlying areas going without care. It’s critical that Medicare understands how these cuts will directly limit access to care, not just for those in remote areas, but potentially for any patient. They need to fully grasp the real-world impact of these changes.
In addition, there is a positive aspect of the proposed rule that deserves your support in your comments, the change to the face-to-face encounter requirement. The proposal would allow any allowable practitioner to complete the face-to-face encounter note, as long as it meets the necessary criteria and falls within the required time frame to support home health services.
For example, when my mother was receiving home health care, her primary care physician certified her for services, but she was also under the care of an oncologist and a cardiologist. The primary care physician permitted the home health agency to accept orders from those specialists as well. If this proposed regulation is finalized as written, any of those physicians would be able to provide the face-to-face encounter documentation.
Additionally, we’ve been advocating for updates to the HHCAHPS survey for years, and this proposed rule includes several significant changes that would finally address many of those longstanding concerns.
Those of you involved in Hospice are likely aware that the CAHPS Hospice Survey has been updated for 2026 to include an email-based option. The proposed rule for Home Health notes that an email version of the HHCAHPS survey has been tested; however, it does not clearly indicate whether the use of email for HHCAHPS submissions is officially part of the proposal. In your comments, be sure to emphasize the importance of including email as an approved method for distributing the HHCAHPS survey.
The most critical element of your comments should focus on the proposed payment cuts and, most importantly, how these reductions would affect your ability to deliver care, and how they could limit your patients’ access to the services they need.
The National Alliance for Care at Home has developed templates, which can be found by clicking here, to help agencies craft effective comments on the proposed rule. There will also be a webinar hosted by the National Alliance for Care at Home on August 7 called “Make Your Voice Heard: Responding to the CY 2026 Home Health Proposed Rule”. To register for this event, please click here.
We are deeply disappointed and frustrated with the content of this proposed rule, particularly the proposed cuts, and we strongly encourage everyone receiving this information to submit comments. There is strength in numbers, and it is vital that they hear directly from individual agencies like yours.
Healthcare Provider Solutions is here to support you with any of your needs, whether it relate to Face-to-Face encounters or guiding you through this open feedback period. For any assistance you might need, please reach out to us.
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