July 8, 2025
Each year, the Centers for Medicare & Medicaid Services (CMS) updates its payment and coverage policies for the various practice settings, including payments to home health agencies (HHAs). CMS released the proposed rule modifying the home health prospective payment system (HH PPS) for Part A services provided to Medicare beneficiaries in 2026 for public comment on June 30. ASHA is reviewing the proposals in the rule and preparing comments, which are due in late August.
CMS proposes to reduce payments to the home health sector by 6.4%, or $1.135 billion, in 2026. This dramatic reduction is the result of a combination of permanent and temporary payment adjustments designed to align payments to HHAs with cost. As noted in the proposed rule, payments to this sector in 2024 exceeded costs by 33%. Because CMS believes it has an obligation to be a good steward of taxpayer dollars, it feels compelled to address the significant profit the industry appears to be achieving.
CMS notes that it continues to see evidence of a reduction in the number of visits HHAs conduct across clinical disciplines—including nursing, physical and occupational therapy, and speech-language pathology—since implementation of the Patient Driven Groupings Model (PDGM) in 2020.
In 2024, for example, approximately 37% of home health patients did not receive any therapy services. In some cases, this might be because the patient did not require therapy. However, ASHA continues to receive anecdotal reports from some speech-language pathologists (SLPs) that administrative mandates imposed by the employer prevented them from providing services to their patients.
In contrast, the two categories under PDGM that trigger a therapy payment—musculoskeletal and neurological rehabilitation—typically received around seven home health visits per 30-day period in 2018 and 2019, the two years prior to the Patient Driven Payment Model (PDPM) implementation. After the transition to PDPM, the average number of therapy visits for patients in these categories began trending downward in 2020. By 2024, patients were receiving closer to five visits per 30-day period.
While ASHA appreciates the need to protect the Medicare Trust Fund, we are concerned such dramatic reductions could cause layoffs or reduced hours or wages for those working in home health—including SLPs—which further compounds patient access issues CMS has previously identified. We also remain committed to ensuring that when a home health patient requires the services of an SLP, those services are rendered.
Find more information on the HH PPS, including resources to help SLPs maintain their clinical and ethical obligations to patients, on the ASHA website.
Under the Home Health Quality Reporting Program, CMS proposes several changes, including elimination of the “COVID-19 Vaccine: Percent of Patients Who Are Up to Date” measure and the item related to the measure and corresponding data element. CMS also proposes to remove four assessment items associated with social determinants of health, including one Living Situation item, two Food items, and one Utilities item.
It also seeks recommendations for measures associated with well-being, cognitive function, nutrition, and interoperability.
For the Home Health Value-Based Purchasing Model, CMS proposes to add four new measures, including the claims-based “Medicare Spending Per Beneficiary Post-Acute Care (MSPB-PAC)” measure and three Outcome and Assessment Information Set (OASIS)-based function measures: Improvement in Bathing, Improvement in Upper Body Dressing, and Improvement in Lower Body Dressing.
CMS proposes a technical regulation text change to the Home Health Conditions of Participation (CoP). These technical changes update terminology in the Home Health CoPs to further clarify that the requirement for reporting OASIS information applies to all HHA patients receiving skilled services, not just Medicare or Medicaid beneficiaries.
CMS also proposes several changes to the Durable Medical Equipment, Prosthetic, Orthotic, and Supplies (DMEPOS) list, including revising the policies associated with DMEPOS accrediting organizations and the competitive bidding program. While SLPs may provide some forms of DMEPOS to their patients, such as transesophageal prosthesis and augmentative and alternative communication devices, they are often not DMEPOS suppliers, so these changes will likely have a limited direct impact on ASHA members.
ASHA will submit comments before the comment deadline. A final rule will likely be released in early November with implementation on January 1, 2026.
Email reimbursement@asha.org.