Now Available: The CMSW CY 2027 Home Health Proposed Rule

by Megan Bernier, MSPT, RAC-CT, CHS-C, COS-C

On July 1, 2026, the Centers for Medicare & Medicaid Services (CMS) issued the Calendar Year (CY) 2027 Home Health Prospective Payment System (HH PPS) Rate Update proposed rule. This proposed rule updates the CY 2027 HHA Medicare payment rates, Home Health Quality Reporting Program (HHQRP) requirements, and other Medicare policies. There are no proposals related to the expanded HHVBP Model.

In addition, the proposed rule requests for information (RFIs) on one topic related to the HHQRP and provides a summary related to potential alignment between the HHQRP and the expanded HHVBP Model. The following highlights are the proposed updates to the HHQRP.

Proposed Changes: HHQRP

Revised HHQRP data submission deadlines:

CMS is proposing that, beginning with the CY 2027 HHQRP, HHAs would be required to complete their data submission and make corrections to their OASIS assessment data where necessary no later than the 15th day of the second month after the end of the calendar quarter. They clarify that if the 15th day of the second month falls on a Friday, weekend, or Federal holiday, the date would be delayed to the next business day. If finalized, this proposal would update the data correction timeframe to the following:

CY Quarter	Data Collection Timeframe	Final Data Submission Deadline for CY 2029 Payment Determination
CY 2027 Quarter 1	January 1 – March 31, 2027	May 17, 2027
CY 2027 Quarter 2	April 1 – June 30, 2027	August 16, 2027
CY 2027 Quarter 3	July 1 – September 30, 2027	November 15, 2027
CY 2027 Quarter 4	October 1 – December 31, 2027	February 15, 2028

Revised HHQRP OASIS and HHCHPAS Annual Payment Update (APU) reporting timeframe

CMS proposes to revise the OASIS and HHCAHPS APU data reporting timeframe to a calendar year instead of the current timeframe which is July 1st through June 30th. If finalized this transition would occur with the 2028 APU.

Additionally, CMS proposed that to make this revision, the APU data reporting timeframe used to determine the HHQRP 2028 APU would be shortened to accommodate this change

OASIS APU Date Timeframe

The 2028 APU would determination would be based on six months of OASIS data, specifically July 1, 2026 through December 31, 2026.

The 2029 APU would be the first iteration in which the APU timeframe would be based on the calendar year, January 1, 2027 through December 31, 2027.

HHACHPS APU Data Timeframe

The 2028 APU determination would be based on nine months of HHCAHPS data, specifically April 1, 2026 through December 31, 2026

The 2029 HHCAHPS data reporting timeframe would be the first iteration in which the APU timeframe would be based on the calendar year, January 1, 2027 through December 31, 2027.

Request for Information

CMS is requesting input on the importance, relevance, appropriateness, and applicability of the quality measure concepts related to advanced care planning and measures appropriate for the HH setting.

Alignment between HHQRP and the expanded HHVBP Model

While no proposals are included in the CY 2027 HH Proposed Rule, CMS did outline several opportunities for potential alignment between the HHQRP and the expanded HHVBP Model. These include:

Increasing alignment in expanded HHVBP Model and HH QRP Quality of Patient Care (QoPC) Star Ratings measure sets.

Aligning HH QRP and expanded HHVBP Model measure reporting periods.

Aligning HH QRP APU and expanded HHVBP Model annual payment reporting periods.

Aligning expanded HHVBP Model Interim Performance and HH QRP QoPC Star Rating Reports.

Aligning timeframe of appeals/suppression review processes for the expanded HHVBP Model and HH QRP.

Updating scoring methodology to incorporate HH QRP APU penalties in expanded HHVBP Model payment adjustments and factoring HH QRP Quality Assessments Only (QAO) values into QoPC Star Ratings scoring.

CMS did state that they are not seeking comments on the list of opportunities but provided the list for general awareness of potential areas of alignment that are being considered.

Reference and Public Comment

Read the complete text of the Home Health CY 2027 Proposed Rule including information on the 60-day public comment period.

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