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CMS released the CY 2027 Home Health Prospective Payment System Final Rule on November 4.

While many agency leaders will understandably focus on reimbursement, I believe the more urgent message is the expansion of Medicare enrollment and program integrity enforcement. My review of the rule identifies new exposure related to retroactive revocations, ownership changes, and provider qualifications. I have repeatedly reminded agencies that regulatory compliance cannot be limited to clinical records or survey preparation. The integrity of your Medicare enrollment information is just as important as the integrity of your patient documentation.

I urge every administrator to review the CMS-855A Medicare Enrollment Application for Institutional Providers, compare the information with the agency’s current organizational chart, including ownership and management structure, and confirm that corresponding PECOS records are accurate. Simply reviewing a paper copy is not a substitute for making required reports or corrections.

Payment Changes Are Only Part of the Story

CMS estimates a 2.4% aggregate increase in home health Medicare payments for 2027, alongside a temporary 3.0% reduction to the national standardized payment rate and changes to PDGM case-mix weights, LUPA thresholds, and outlier calculations. These figures should not be mistaken for a uniform increase in every agency’s reimbursement.

CMS is also shortening the OASIS submission deadline from 135 to 45 days. Agency leaders must look beyond the headline payment percentage and determine what these changes mean for their own patient mix, documentation, billing processes, and quality reporting. Technology can help, but only when agencies use it consistently.

Enrollment Compliance Is a Leadership Responsibility

Deborah (Deb) Hoyt, Senior Vice President of Public Policy at Axxess, captures the enrollment concern well: “This represents a substantial increase in financial exposure for providers that fail to maintain compliance with Medicare enrollment requirements.”

If an agency discovers outdated ownership information on its CMS-855A, an unreported management change, or a licensing problem only after a Medicare review begins, it may already be too late to avoid significant consequences. Importantly, the Final Rule does not announce that the existing enrollment moratoria have been lifted.

Owners considering a purchase, expansion, or change in majority ownership should verify applicable requirements before moving forward. Education must be part of the solution. Axxess Training and Certification can support ongoing staff competency in documentation, OASIS accuracy, workflow consistency, and compliance awareness when paired with agency-specific policies, oversight, and follow-up. A certificate alone does not establish compliance.

Hospice Providers Should Pay Attention

While this is a Home Health Final Rule, hospice providers should not assume these changes do not apply to them. CMS has finalized Medicare enrollment and program integrity provisions that directly affect hospices, particularly those involving changes in majority ownership, provider qualifications, and retroactive enrollment revocations.

Hospice administrators and governing bodies should review their CMS-855A enrollment information, PECOS records, ownership disclosures, and organizational structure now. These are not simply administrative details. Failure to maintain accurate enrollment information could jeopardize Medicare participation and expose an organization to significant repayment demands.

Additional Final Rule Provisions Agencies Should Not Overlook

OASIS and quality reporting deserve particular attention. Beyond the shortened OASIS submission deadline already noted, CMS finalized changes to HH QRP assessment submission deadlines beginning with the CY 2027 program year and aligned OASIS and HHCAHPS Annual Payment Update reporting time frames to a January 1 through December 31 calendar year.

Palliative care is another area agencies should understand before making changes to their service lines. CMS recognizes that eligible home health patients with serious or progressive illnesses may need skilled palliative services as part of their care. However, the Final Rule does not create a new separately paid home health palliative care benefit.

CMS did not finalize new policies specific to the expanded HHVBP Model, although it discussed opportunities to better align HHVBP and HH QRP. The rule also discusses a possible home health-specific wage index, but that discussion is a request-for-information follow-up, not implementation of a new wage index for 2027.

Finally, the rule expands the Medicare Part B durable medical equipment definition for certain external infusion pumps and associated home infusion drugs, effective April 1, 2027, when specified conditions are met.

5 Recommendations for Organizations

1. Review your Medicare enrollment file. Compare the CMS-855A and PECOS records with current ownership, managing employees, practice locations, licenses, and required disclosures. Review your organizational chart at least quarterly and at each scheduled board meeting.
2. Evaluate ownership transactions before signing. Determine whether a contemplated change triggers new enrollment, survey, or accreditation requirements.
3. Review your actual 2027 reimbursement using agency-specific PDGM, LUPA, acuity, and utilization information.
4. Audit OASIS and documentation workflows. Verify successful OASIS submission and acceptance within the new deadline.
5. Make compliance education part of QAPI. Use Axxess Training and Certification, along with internal competencies and audits, to reinforce accurate assessments, timely documentation, and accountability.

Upcoming Live Discussion:

From Rule to Reality: Making Sense of the Home Health Final Rule

Join us for our upcoming webinar as home health leaders discuss understanding the rule and prepare their organizations for what comes next.