Calendar Year 2027
August 31, 2026
Electronic Submission via Regulations.gov
The Honorable Mehmet Oz, MD
Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1844-P
7500 Security Boulevard
Baltimore, MD 21244-1850
Re: CMS-1844-P, Calendar Year 2027 Home Health Prospective Payment System (HH PPS) Proposed Rule
Dear Administrator Oz:
Well Care Health (“Well Care”) thanks the Centers for Medicare & Medicaid Services (“CMS”) for the
opportunity to respond to the CY 2027 Proposed Rule (“Proposed Rule”) and respectfully submits the following information regarding the impact of the Proposed Rule on Well Care Health and the communities we serve. In addition to these comments, Well Care supports the broader points and concerns raised by the comments submitted by the National Alliance for Care at Home (“Alliance”).
As background, Well Care is a family-owned and operated home health and hospice provider with a patient census of over 5,000, serving communities across 43 counties in North Carolina and South Carolina. Well Care has been repeatedly recognized as a national leader in quality of care, including earning a five-star Quality of Patient Care Star Rating from CMS. Our comprehensive service offerings provide critical support for patients in their path to independence and self-care in the comfort of their own homes, and our top priority is placing the needs of our patients first. With nearly 40 years of experience in home-based care, including more than 25 years as a Medicare-participating provider, we are well-positioned to share valuable insights with CMS regarding the foreseeable impact of the Proposed Rule on our organization, as well as the patients and communities we serve across the Carolinas. Well Care is a proud member of the Alliance and the Association for Home & Hospice Care of North Carolina (“AHHC”).
Specifically, we emphasize the following points for consideration:
- Home health care represents a powerful value proposition for patients and the Medicare Program as the lowest-cost care setting, warranting policy that supports and reinforces a strong and sustainable Home Health benefit;4. Given that annual recalibration of PDGM payment components creates continued operational uncertainty for providers that negatively impacts our ability to plan and make needed investments, we encourage CMS to explore ways to promote greater year-over-year stability and predictability in the payment model;
- Access to home health remains a serious concern in our service area following an extended period of financial pressure associated with substantial cost inflation and reimbursement pressure, with access challenges especially prevalent for rural, higher-acuity, and otherwise difficult-to-serve patient populations;
- Well Care appreciates the payment increase in the Proposed Rule, but in the context of the compounding impact of multiple years of payment cuts, we: (a) oppose continued permanent and temporary behavioral adjustments under the current PDGM methodology; (b) urge CMS not to finalize the proposed 3% temporary adjustment; and (c) ask CMS to reconsider prior permanent behavioral adjustments where the underlying methodology does not reliably distinguish changes caused by PDGM from other changes in the home health environment;
- Given that annual recalibration of PDGM payment components creates continued operational uncertainty for providers that negatively impacts our ability to plan and make needed investments, we encourage CMS to explore ways to promote greater year-over-year stability and predictability in the payment model;
- Well Care supports CMS’s exploration of a home health-specific wage index, but opposes using current home health cost reports as a basis for this index without first improving the accuracy, consistency, and usefulness of the cost reporting system;
- Well Care supports CMS’s goal of expanding appropriate access to palliative care through the Medicare home health benefit, but believes significant operational and payment questions must be addressed and clarified before providers can implement this direction consistently;
- Well Care supports efforts to streamline quality reporting and improve alignment between Quality of Patient Care Star Ratings and HHVBP measures, and encourages CMS to use this opportunity to discontinue unnecessary or non-value-additive OASIS items to reduce the administrative burden shouldered by our clinical workforce; and
- Well Care strongly supports targeted efforts to prevent fraud, waste, and abuse, but opposes overly vague and expansive provider enrollment restrictions that do not clearly distinguish legitimate providers from bad actors.
