What’s Changing for Medicare Home Health Under the 2026 Final Rule?

A Practical Breakdown for Medicare-Certified Agency Owners & Leadership

Payment cuts. HHVBP risk. New HHCAHPS changes. Tighter enrollment rules. For many agency leaders, the 2026 Final Rule feels like another year of doing more with less. All while your agency is protecting your patient census, cash flow, and survey outcomes.

The concern isn’t just “What did CMS change?”
It’s how those changes ripple through intake, staffing, billing, audits, and revenue stability.

*This article was written in consultation with Mariam Treystman.

At The Home Health Consultant, we work directly with Medicare-certified home health agencies on compliance systems, survey readiness, and operational performance. We wrote this guide to translate the CY 2026 Home Health Final Rule into plain-language so it’s easier to understand what to expect.

Everything below is based strictly on:

• CMS’s official 2026 Home Health Final Rule fact sheet
• ACHC’s summary to accredited agencies

When something is still unclear, we say so. There’s no speculation framed as fact.

Is Medicare Cutting Home Health Payment Rates in 2026?

Yes, Medicare is cutting home health payment rates in 2026. But the final cut is smaller than originally proposed.

CMS originally projected a reduction of roughly $60 per 30-day payment period, a number that raised serious concern across the industry. In the final rule, that projection was revised downward.

ACHC reports the finalized impact is closer to $19 less per 30-day period. CMS confirms that total Medicare home health spending in 2026 will decline by about –1.3% ($220 million) compared to 2025. 

So why did CMS reduce the size of the cut?

CMS used updated 2024 claims data to reassess how agencies actually behaved under PDGM. This was compared to what CMS originally assumed when PDGM launched in 2020. Based on that newer data, CMS reduced the amount of the permanent adjustment.

Now let’s take a look at how the Patient Driven Grouping Model, PDGM, is changing in 2026.

How Is PDGM Being Recalibrated for Home Health Agencies in 2026?

Beyond the payment rate itself, CMS is adjusting the mechanics that determine how each 30-day episode is paid.

For 2026, CMS finalized:

• –1.023% permanent adjustment

• –3.0% temporary adjustment

• –0.1% related to outlier payment recalibration

CMS is also updating the underlying PDGM groupings using 2024 utilization data, including:

• Recalibrated case-mix weights
• Updated LUPA thresholds
• Updated functional impairment levels
• Updated comorbidity subgroupings

CMS does not specify:

• Which clinical groups will be most affected
• How large the reimbursement shifts will be
• How agencies should rebalance visit planning proactively

Historically, agencies only see the real impact once pricing files and early 2026 claims begin posting.

Who Can Perform the Face-to-Face Encounter Under the 2026 Home Health Final Rule?

This is one of the most meaningful regulatory clarifications in the final rule.

As of 2026, CMS allows the following practitioners to perform the face-to-face encounter:

• Physicians
• Nurse Practitioners
• Clinical Nurse Specialists
• Physician Assistants

And importantly, the practitioner who performs the face-to-face does NOT have to be the certifying provider.

This change is intended to reduce admission delays, physician bottlenecks, and avoidable SOC postponements. It should offer some needed relief to agencies that have been struggling with F2F compliance.

What’s Changing in the Home Health Quality Reporting Program (OASIS & HHCAHPS)?

CMS finalized several updates that affect OASIS and public reporting.

Measures being removed:

• COVID-19 vaccination measure

• Four standardized patient assessment data items:
  • 1 Living Situation item
  • 2 Food items
  • 1 Utilities item

These changes may slightly reduce data-entry time, but generally expectations around documenting social risk, safety, and environmental assessment remain the same.

When does the new HHCAHPS survey begin?

CMS confirmed the revised HHCAHPS survey begins with the April 2026 sample month. This change directly affects public reporting and HHVBP scoring.

Is OASIS now required for all skilled patients?

Yes OASIS is now required for all patients, regardless of payer. This means even if you’re treating a patient who is not covered through Medicare, they must still have an OASIS. 

For a more detailed breakdown of the all-payor OASIS update, check out the article below.

Agencies have already adjusted to accommodate all-payor OASIS, but the final rule has now removed any regulatory ambiguity.

How Is HHVBP Changing in 2026?

Because HHCAHPS is changing, CMS is also reshaping the Home Health Value-Based Purchasing (HHVBP) Program.

The following HHCAHPS-based measures are being removed in April 2026:

• Care of Patients
• Communications Between Providers and Patients
• Specific Care Issues

In addition to these removals, CMS is adding four new measures:

• Medicare Spending per Beneficiary – Post-Acute Care (MSPB-PAC) (claims-based)
• Three OASIS-based functional measures focused on:
  • Bathing
  • Dressing
  • Functional activities involving safety and medications

ACHC explains these measures are intended to evaluate:

• Home safety discussions
• Medication reconciliation (Rx + OTC)
• Medication side-effect education

CMS also confirmed that HHVBP category weighting will shift to reflect the new mix.

Are Provider Enrollment Rules Tightening for Home Health Agencies Under the 2026 Home Health Final Rule?

Yes, enrollment rules will be tightening for home health agencies in 2026. CMS finalized several program-integrity updates.

Key enrollment changes include:

• Adverse legal actions must now be reported within 30 days (previously 90).

• Expanded authority for denial, deactivation, and revocation

• Broader use of ‘retroactive revocation’
  • *Retroactive revocation means CMS can revoke billing privileges back to the start of noncompliance, potentially triggering recoupment of already-paid claims.

CMS does not state how aggressively this will be enforced, but past similar changes have led to tighter scrutiny from auditors & surveyors.

How Will the 2026 Final Rule Likely Affect Daily Home Health Operations?

CMS does not explicitly describe what these changes look like inside real agency workflows. Based on how similar shifts have played out in prior years, here’s where we think agencies are most likely to feel pressure:

1. Greater Visit Utilization Pressure

Lower reimbursement plus recalibrated LUPAs means:

• Visit counts matter more
• Therapy utilization will be scrutinized
• Comorbidity capture at SOC has greater financial impact

2. Face-to-Face Flexibility May Reduce Delays, but Increase ADR Risk

More flexibility at SOC also means:

• Higher scrutiny when performing and certifying providers differ
• Stronger documentation expectations connecting the two

3. HHVBP Performance Will Shift Away From Satisfaction Alone

With multiple satisfaction-based measures removed, HHVBP risk will increasingly come from:

• Documented functional improvement
• Medication education
• Cost efficiency

4. Faster Enrollment Compliance Will Be Required

With only 30 days to report adverse actions:

• Internal reporting pipelines must move faster
• Ownership, legal, and leadership shifts require tighter monitoring

Common Questions Agencies Are Asking About the 2026 Final Rule

Q: Does the new HHCAHPS change how HHVBP is scored?
A: Yes. Several HHCAHPS-based measures are being removed from HHVBP and replaced with functional and spending-based measures beginning April 2026.

Q: Does OASIS now apply to private-pay skilled patients?
A: Yes. CMS formally clarified that OASIS applies to all skilled patients, regardless of payer.

Q: Can a different physician now perform the face-to-face?
A: Yes. The provider performing the F2F does not have to be the certifying provider.

Q: Will PDGM recalibration automatically increase or decrease my revenue?
A: It depends on your agency’s case mix, functional scoring, comorbidity capture, and visit utilization. CMS does not publish predictive agency-specific impact.

What Is the Biggest Takeaway for Home Health Agencies in 2026?

The 2026 Final Rule doesn’t overhaul Medicare home health, but it tightens the system in meaningful ways. Between…

• lower reimbursement,
• PDGM recalibration,
• a new HHCAHPS survey,
• shifting HHVBP measures,
• and stricter enrollment oversight

…the pressure is clearly moving upstream. Having a strong administrative compliance system in place is more important now than ever. 

Agencies that already run tight front-end workflows and monitor compliance continuously will likely feel the least disruption. Agencies that rely on reactive fixes between surveys may find 2026 far less forgiving.

If HHVBP is still something you’re working to understand at a deeper level, we break it down clearly here:

*Disclaimer: The content provided in this article is not intended to be, nor should it be construed as, legal, financial, or professional advice. No consultant-client relationship is established by engaging with this content. You should seek the advice of a qualified attorney, financial advisor, or other professional regarding any legal or business matters. The consultant assumes no liability for any actions taken based on the information provided.