Federal Home Health and Hospice Updates
(April 22, 2025) Members are encouraged to review LeadingAge National's updates for both home health and hospice providers:
CMS Releases April 2025 Quarterly OASIS Q&A. The Centers for Medicare and Medicaid Services (CMS) released April 2025 Outcome and Assessment Information Set (OASIS) Questions and Answers (Q&A). This document is updated on a quarterly basis and is intended to provide guidance on OASIS questions that were received by CMS help desks. As a reminder, responses may be time-limited and may be superseded by future CMS guidance.
Note for all certified home health agencies (CHHAs), regardless of payor: This quarter's OASIS questions go into detail about the new requirements for all-payor OASIS collection and provide agency-specific examples of scenarios where OASIS may or may not be required. As a reminder, OASIS collection on all patients is voluntary as of Jan. 1, 2025. However, on July 1, 2025, all agencies will be required to submit OASIS documents on all patients regardless of payor except in limited circumstances. CMS previously addressed these limited circumstances in guidance; however, additional considerations are detailed in this quarterly Q&A.
CMS Final CY 2026 MA Policy Rule to Be Published April 15th. The final Calendar Year 2026 (CY 2026) Medicare Advantage (MA) Policy and Technical rule is currently listed under Public Inspection with the Federal Register as of April 4th, but will be officially published on April 15th. This is a final rule and is about 60 percent of the length of the proposed rule. The rule finalizes provisions to improve integration for dual-eligibles enrolled in applicable integrated dual-eligible special needs plans (D-SNPs) and adopts changes clarifying MA plan determinations and enrollee protections in inpatient settings. On the latter, LeadingAge National will need to review the detail to see if member interests were addressed by the final language. LeadingAge National staff will be reviewing the rule in detail in the coming days, and a summary article will follow. These rules will take effect June 3, 2025, though the bulk of the provisions will take effect for MA coverage beginning Jan. 1, 2026.
CMS Finalizes Two MA Rules. CMS finalized two rules governing the policies and payments for MA plans in CY 2026. Both rules were proposed under the Biden administration and just finalized by the Trump administration, but with some changes. LeadingAge National will be writing up a summary of the two rules in the coming week and discussing the rules and their implications in more detail at their May 3rd Managed Care Solutions Network meeting. Members who have not yet joined the Network can do so here.
Historically, States Facing Reduced Federal Medicaid Dollars Cut HCBS. Health Affairs published an article on April 16th authored, in part, by Marc Cohen and Jane Tavares of the LeadingAge Long-Term Services and Supports (LTSS) Center at UMass Boston. The article makes the case for why home and community-based services (HCBS) are likely first to see programmatic reductions if Congress makes changes to the Medicaid program. The authors lay out facts about spending on HCBS and discuss how states responded during the fiscal crisis of 2008. Congress shored up state budgets providing increased federal participation (via enhanced Federal Medical Assistance Percentage (FMAP)) though 2010, though when these subsidies dried up, 47 states spent less per person on HCBS, and 40 states served fewer people. The article continues by laying out the tenuous relationship between states and HCBS payment rates, noting rates are already too low to sustain the industry. Providers are exiting the market despite high demand, and the rates are inadequate to provide quality wages to the workforce, leading to challenges in hiring enough staff to meet demand. Authors contend that Medicaid cuts by Congress will cause states to make changes to HCBS programs, including reductions in services available or numbers of people served. States could even see a growth in nursing facility utilization, as decreases in HCBS offerings do not mean fewer people need services. Read the article here.
Summary: FY 2026 Hospice Wage Index Proposed Rule. Posted to the Federal Register on April 11th, the Fiscal Year 2026 (FY 2026) Hospice Wage Index, which includes a minimal update to payment and a number of requests for information, is scheduled for publication in the Federal Register on April 30th. Read a full detailed article on what is included in this rule here.
CMMI Releases Hospice VBID Findings. The Center for Medicare and Medicaid Innovation (CMMI) released findings of the Value-Based Insurance Design (VBID) Model's hospice component for 2021-2023. This demonstration tested a broad array of MA health plan innovations that aim to enhance the quality of care for Medicare enrollees, including hospice. Early in 2024, CMS announced that the VBID hospice component would conclude at the end of 2024 and later in 2024 similarly announced that the entire VBID demonstration would be shuttered. The brief findings identify that 2023 had the highest number of participating plans for the entire demonstration: 15 insurers across 115 plans. Most insurers had broad geographic reach, were in areas of high MA penetration, and had a high proportion of dually eligible beneficiaries. Over time, CMMI found that more hospices were considered "in-network," growing from 37 percent in 2021 to 55 percent in 2023. Some insurers reported that they needed to contract with many more hospices than in prior years to meet network adequacy requirements. Looking at benefits, CMMI found that palliative care and transitional care were less well-used. The outcomes also began to shift in 2022 with an increase in short lengths of stay, a decrease in live discharges, and a decrease in visits in the last days of life. Challenges with the model remained for hospices, including low reimbursement rates, delayed payments, varying data reporting and communications requirements, and a lack of standardized benefits for palliative and transitional care. Some of these barriers were cited in CMMI's decision to discontinue the program. A final year of reporting for the program, covering the final year of services in 2024, will likely be released next year.
Contact: Meg Everett, meverett@leadingageny.org, 518-867-8871