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AAPA Submits Comments in Response to 2026 Home Health Prospective Payment System Rate Update Proposed Rule

Comments call attention to outdated policies creating inefficiencies in home health care delivery

August 20, 2025

AAPA recently filed comments in response to the 2026 Home Health Prospective Payment System Rate Update proposed rule, urging the Department of Health and Human Services (HHS) to address several outdated policies creating inefficiency in care delivery.

Filed on August 18, AAPA’s comments also highlight areas of support in addition to calling HHS’ attention to necessary payment adjustments and quality reporting improvements.

  • Support for Face-to-Face Encounter Change:Current CMS policy requires the face-to-face and certification encounters be performed by the same qualified practitioner (which includes PAs). AAPA endorses CMS’s proposal to remove the requirement that the encounters be performed by the same qualified practitioner, promoting efficient and coordinated care.
  • Request to Authorize PAs for DME Orders:AAPA urges CMS to permit PAs to provide documentation and certification for home blood glucose monitors, citing statutory authority and evidence that PAs deliver comparable diabetes care to physicians.
  • Concerns Over Payment Rate Cuts:AAPA expresses concern about a nearly 10% payment reduction proposed for 2026, fearing it may reduce access and quality of home health care, especially given prior cuts and the exclusion of Medicare Advantage data in CMS’s analysis.
  • Support for Streamlining Data Reporting:AAPA supports CMS’s proposal to shorten the data submission deadline for the Home Health Quality Reporting Program from 4.5 months to 45 days, enhancing timeliness and actionability of quality feedback, while recommending alignment of all related reporting programs.
  • Caution on Removing Social Determinants of Health Measures:While approving burden reduction, AAPA advises reconsideration of removing four social determinants of health data elements, emphasizing their role in identifying barriers to care and improving outcomes.
  • Support for Future Quality Measures:AAPA supports adding interoperability, cognitive function, patient well-being, and nutrition as future quality measure concepts, highlighting the importance of validated tools and clinical feasibility.
  • Interoperability Importance:AAPA recognizes interoperability as key to efficient care coordination among patients, providers, and payers, endorsing CMS efforts to measure and promote system readiness.
  • Professional Title Clarification:AAPA requests that CMS refer to physician assistants as “physician assistants/physician associates” to reflect the profession’s recognized dual titles and uniform certification and scope of practice.

Read AAPA’s letter.

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