A massive regulatory overhaul looms on the horizon for home health agencies. The proposed Calendar Year 2026 Home Health Payment Update rule spans nearly 600 pages, packed with changes that extend far beyond payment adjustments.

• Proposed expansion of face-to-face encounter policy to allow not just physicians but also NPs, CNSs, and PAs to perform encounters regardless of prior patient relationship
• CMS plans to remove COVID-19 vaccine reporting measure and four social determinants of health assessment items from OASIS data collection
• Proposed shorter HHCAHPS survey implementation beginning April 2026 with fewer questions
• Potential reduction in data submission timeframes from 4.5 months to 45 days to improve measure timeliness
• Updates to Home Health Value-Based Purchasing including measurement changes and reweighting of components
• Technical updates to Conditions of Participation text to accommodate all-payer OASIS data submission
• Multiple requests for information on interoperability, wellness measures, and falls reporting

Comments on these proposed changes must be submitted to CMS by August 29th. The final rule is expected to be published in late October or early November.

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Case management represents the invisible thread that weaves together all aspects of patient care in home health and hospice settings—yet many clinicians receive minimal training in this critical skill.

The conversation between Jennifer Kennedy and Kim Skehan dives deep into what effective case management looks like and why it matters so profoundly for both patient outcomes and regulatory compliance. As Kim notes, "Case management is a next level skill" that requires dedicated training and support beyond what most clinicians receive in their professional education. Organizations must invest in developing these capabilities, recognizing that quality case management takes months—not days—to cultivate.

Beyond simply making visits, case management involves comprehensive assessment, holistic care planning, and coordination across disciplines to address all patient needs. When done well, it improves patient outcomes, prevents complications, and creates seamless care transitions. When it falters, the consequences can be severe, with many survey findings at the condition level or immediate jeopardy stemming directly from coordination failures. This reality highlights the intersection where compliance meets quality—where doing right by patients simultaneously protects organizations from regulatory challenges.

With increasing patient acuity in home-based care, case management has become more complex and demanding. Today's case managers must effectively coordinate multidisciplinary teams, manage high-complexity patients, and ensure comprehensive documentation of all care activities. While technology and AI provide increasingly valuable support tools, the human elements of assessment, coordination, and communication remain irreplaceable. The most successful organizations combine robust training programs with clear processes and adequate time allowances for this vital function.

Ready to strengthen your organization's case management practices? Explore CHAP's Center for Excellence for resources, educational offerings, and disease program certifications that can enhance your team's ability to deliver truly coordinated, patient-centered care.

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The fiscal year 2026 proposed hospice rule brings cautious optimism to providers with a projected 2.4% payment increase, though experienced hospices know to factor in the ongoing 2% sequestration when calculating their bottom line. For those who've long struggled with regulatory inconsistencies, this rule delivers welcome clarification on who can certify hospice eligibility, aligning payment regulations with Conditions of Participation after years of confusion.

Most significantly, CMS confirms the HOPE assessment tool will launch on October 1, 2025, as scheduled. Despite earlier speculation about potential delays, hospices should maintain implementation momentum, with CMS planning one final training session this summer. Face-to-face attestation requirements also receive much-needed clarification, potentially reducing one of the top reasons for claim denials.

Beyond operational updates, CMS seeks provider input through several Requests for Information. They're exploring digital quality measurement using FHIR-based reporting, considering new quality measures around well-being and nutrition, and looking for opportunities to streamline regulations and reduce administrative burden. This represents a genuine opportunity for hospice providers to shape future requirements.

The relatively slim 62-page rule contains consequential changes that demand attention. Providers should thoroughly review the complete document, evaluate potential financial impacts, coordinate with state and national associations on comments, and ensure staff education aligns with the clarified regulations. With the comment period closing June 10 and the final rule expected in early August, the time to prepare is now. Let your voice be heard on these important changes that will influence hospice care delivery and reimbursement for years to come.

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