Compliance Monitor (09/15/2025)
Your source for federal updates.
September 2025 Compliance Activity
| CY 2026 Home Health Payment Update Rule comment due Correction: Comments to CMS due Sep 2, 2025 | Comments are due to CMS on Sep 2, 2025. Instructions for submitting comments appear in the beginning of the rule. |
| September 10, 2025 | Hospice providers must register for access to iQIES. Information and instructions to register for an PSO iQIES account, please visit: https://qtso.cms.gov/news-and-updates/iqies-hope-assessment-submission-and-reporting-launch-and-provider-security. |
| Telehealth Extension Extension expires Sep 30, 2025 | Without Congressional action, key telehealth flexibilities that have been in place since the COVID-19 pandemic will expire on September 30, 2025. The extension of these flexibilities were tied to the federal continuing resolution.https://www.congress.gov/bill/119th-congress/house-bill/1968/text?s=2&r=1&q=%7B%22search%22%3A%22telehealth%22%7D#toc-H1605045683F94C959D531FAF6124375C |
| CMS HQRP Compliance Reconsideration Results | Reconsideration results delivered in August/ September |
Top Items
CMS Posts Medicaid Hospice Payment Rates
The memorandum contains the Medicaid hospice payment rates for federal fiscal year (FY) 2026. The rates reflect changes made under the final Medicare hospice rule published on August 1, 2025 (CMS-1835-F). Please inform your staff and all state agencies in your jurisdiction of these new payment rates, which are effective October 1, 2025.
DME: Complying with Proof of Delivery Requirements
The Comprehensive Error Rate Testing (CERT) Task Force identified missing or incomplete proof of delivery (POD) documents for DME claims. You’re required to maintain POD documentation for 7 years from the date of service regardless of your delivery method.
Use the CERT DME POD Requirements (PDF) work guide to learn what you must include and what’s required for each delivery method.
More Information:
- Standard Documentation Requirements for All Claims Submitted to DME MACs article
- Medicare Program Integrity Manual, Chapter 4 (PDF), section 4.7.3.1.1–4.7.3.1.3
- CERT webpage
Complying with Medicare Signature Requirements Revised
CMS added information (PDF) on:
- Stamped signatures
- Artificial intelligence
- Signature attestations and logs
Enforcement Alert: Information Blocking
Stopping information blocking to unleash innovation and empower patients and their health care providers with friction-free information is a top priority for the Secretary of the Department of Health and Human Services and the Administration. The Office of Inspector General and the Office of the Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology are issuing an enforcement alert to signal our joint commitment to intensify enforcement activity, dedicate additional resources, and take decisive action to detect and end information blocking.
Read the Alert
CMS IDea Challenge: Submit Interest Form by September 26th
CMS) is hosting two in-person events to combat fraud involving health plan identifiers (ID) and enhance the security of those IDs. These collaborative events will bring together experts from diverse backgrounds to develop innovative ways to protect patient information.
Attendees will spend a full day working in small teams of diverse, professional backgrounds to develop ideas to improve member ID security. At the end of the day, each group will pitch their solutions to CMS and vote on a winning concept.
CMS is seeking participants who can offer varied perspectives to better protect patient information. No advance preparation is required and you do not need technical skills to participate.
Event Dates:
- November 5, 2025, 9:00 AM – 5:00 PM PST, San Francisco, California
- November 13, 2025, 9:00 AM – 5:00 PM EST, New York, New York
To learn more, view the event webpage. To participate, submit an interest form by September 26, 2025.
CDC’s Advisory Committee on Immunization Practices to Meet September 18-19
ATLANTA, GA—SEPTEMBER 12, 2025—The Centers for Disease Control and Prevention’s (CDC) Advisory Committee on Immunization Practices (ACIP) will hold a meeting on Thursday and Friday, September 18-19, 2025, in Atlanta, GA.
The ACIP comprises leading medical and public health experts to advise the CDC on the safety, effectiveness, and clinical necessity of vaccines.
WHEN:
Thursday, September 18
10 a.m. – 5 p.m. ET
Friday, September 19
8 a.m. – 4 p.m. ET
WHERE:
CDC Campus
RSVP:
Media interested in attending in person must request credentials by 12:00pm on Monday, September 15, by emailing mediarsvp@cdc.gov.
Media will receive access information by 1 p.m. on Wednesday, September 17.
Additional Information:
- The meeting will be available to the public via live webcast. The link will be available Thursday morning on the ACIP website.
- The September 18-19 meeting draft agenda will be available on the ACIP website.
Hospice/Palliative Care Provider Updates
UPDATED RESOURCES AVAILABLE: HQRP: Achieving a Full Annual Payment Update (APU) Training
UPDATED RESOURCES AVAILABLE: HQRP: Achieving a Full Annual Payment Update (APU) Training
The Centers for Medicare & Medicaid Services (CMS) is offering a recorded presentation that provides an overview to the Annual Payment Update (APU) for HQRP.
- To access the training, click on the following link: https://youtu.be/8fsh5np1wzg
- A copy of the slides and a transcript of this presentation can be found in the downloads section at the bottom of the HQRP Training and Education Library
If you have questions about accessing resources or feedback regarding training, please email the PAC Training Mailbox
RESOURCES AVAILABLE: HOPE Coding Workshop Final Materials
Downloadable materials including transcripts and PDF copies of the slides from the live coding workshop held on August 5, 2025 are available on the Hospice Quality Reporting Training and Education Library webpage. To access the training, click on the following link: https://www.youtube.com/watch?v=8fsh5np1wzg
This document corrects typographical errors in the final rule that appeared in the August 5, 2025, Federal Register titled “Medicare Program; FY 2026 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Program Requirements” (hereinafter referred to as the “FY 2026 Hospice final rule”). The effective date of the FY 2026 Hospice final rule is October 1, 2025. DATES: This correction is effective October 1, 2025.
Updates to the Hospice Preview Reports for the November 2025 Refresh – NOW AVAILABLE IN QIES
The Centers for Medicare & Medicaid Services (CMS) has updated and re-released the Hospice Provider Preview Reports, which are now available for review by providers. These revised reports contain updated claims-based performance scores for quality measures. Providers can now access the latest Provider Preview Reports via the Certification and Survey Provider Enhanced Reports (CASPER) application. These reports contain provider performance scores for quality measures, which will be published on the compare tool on Medicare.gov and the Provider Data Catalog (PDC) during the November 2025 refresh.
In the Provider Preview Reports, HIS measure scores are based on HIS data submitted by hospices from Quarter 1, 2024 through Quarter 4, 2024. CAHPS measure scores are based on CAHPS data submitted from Quarter 1, 2023 through Quarter 4, 2024. CAHPS Star Ratings are calculated based on data from Quarter 4, 2022 through Quarter 3, 2024. The claims-based measures reflect claims data collected from Quarter 1, 2023 through Quarter 4, 2024.
Once released in CASPER, providers will have 30 days during which to review their quality measure results. The preview period for the latest Provider Preview Report lasts from August 29, 2025 to September 29, 2025. Although the actual “preview period” is 30 days, the reports will continue to be available for another 30 days, or a total of 60 days. CMS encourages providers to download and save their Hospice Provider Preview Reports for future reference, as they will no longer be available in CASPER after this 60-day period.
Learn more about the Provider Preview Report (HIS and Claims-based measures) here and about the CAHPS Preview Report here. Hospice QRP Key Dates for Providers can be found here. The 3rd Edition HQRP Public Reporting Tip Sheet is available here
Home Health Provider Updates
DME Provider Updates
Home-Based Noninvasive Positive Pressure Ventilation to Treat Chronic Respiratory Failure Due to Chronic Obstructive Pulmonary Disease
Learn about updates (PDF) effective June 9, 2025, including updated Medicare coverage guidance for:
- Respiratory assistance devices
- Home mechanical ventilators
Your Medicare Administrative Contractor will adjust claims you bring to their attention.
Orthopedic Footwear: Prevent Claim Denials
In 2023, the improper payment rate for orthopedic footwear was 100%, with a projected improper payment amount of $4.3 million (see 2023 Medicare Fee-for-Service Supplemental Improper Payment Data (PDF)). Learn how to bill correctly for these services. Review the Orthopedic Footwear provider compliance tip for more information, including:
- Billing codes
- Denial reasons and how to prevent them
- Documentation requirements
Home Infusion Therapy Updates
Medicare Part B Updates
Federal Reports Updates
All Providers Updates
The Quality, Safety & Oversight Group (QSOG) and Survey & Operations Group (SOG) remain dedicated to ensuring the health and safety of all Americans. The Fiscal Year (FY) 2026 MPD reflects this dedication, along with our ongoing commitment to strengthen oversight, enhance enforcement, increase transparency, and improve quality of care. The MPD structure includes three sections:
(1) a spotlight on new policy or reinforcement of existing policy since the issuance of the previous FY MPD;
(2) standing general information; and
(3) a listing of the priority tier structure for survey & certification activities for all certified provider and supplier types. This administrative memo represents the final communication of the MPD updates through this format. Beginning in FY 26, the MPD tier table and all accompanying documents will be updated and published directly on the CMS QSOG MPD website prior to the beginning of each fiscal year, or as necessary.
OCR Releases Updated HIPAA Security Risk Assessment Tool
The HHS Office for Civil Rights (OCR) has released version 3.6 of its free Security Risk Assessment Tool (SRA Tool). Designed for HIPAA-covered entities and business associates—especially small and medium providers, the SRA Tool helps with security risk assessments. This update adds features like “reviewed by” for tracking internal approvals and improved reporting to document reviews and approvals.
OCR and the Assistant Secretary for Technology Policy (ASTP) will host live webinars on September 15 at noon ET and September 16 at 3pm ET to walk through the new features and answer questions. Recordings of the webinars will be made available for those who cannot attend live. Based on past webinars, attendees will get the most value out of the webinar if they have already downloaded the updated Tool and associated user guide ahead of time.
To accommodate the busy schedules of small and medium practices, there are two opportunities to attend this webinar live. They are:
Monday, September 15 at Noon ET Register for this session.
Tuesday, September 16 at 3pm ET Register for this session
Information for the 2025–26 influenza season includes the updated vaccine composition, approval of FluMist (nasal spray live attenuated influenza vaccine) for self-administration or caregiver administration, expansion of the approved age threshold for Flublok (recombinant influenza vaccine) from ≥18 years to ≥9 years, and a recommendation that only single-dose seasonal influenza vaccines not containing thimerosal as a preservative be used.
COVID-19 Vaccine Pricing for 2025–2026 Season
CMS updated COVID-19 payment allowances for the 2025–2026 season. Visit the Vaccine Pricing webpage for the most current list of billing codes, including short descriptors and effective dates.
There’s 1 new code for this season. CPT code 91323 is effective August 27, 2025:
- Long descriptor: MNEXSPIKE COVID-19 mRNA (2025-2026) 10 mcg/0.2 mL, single dose High Risk 12-64Y/Over 65Y
- Short descriptor: SARSCOV2 VAC 10 MCG/0.2ML IM
National Fee Schedule for Vaccine Administration: October 2025 Update
Learn about coding updates (PDF) for:
- AVTOZMA® for post-exposure prophylaxis or COVID-19 treatment
- Newly FDA-approved products not yet assigned to a unique HCPCS Level II code
HHS Drives Reform to Restore Patient-Centered Care, Announces Request for Nominations of Members to Serve on Federal Healthcare Advisory Committee
HHS and CMS are establishing the Healthcare Advisory Committee—a group of experts charged with delivering strategic recommendations directly to HHS Secretary Robert F. Kennedy Jr. and CMS Administrator Dr. Mehmet Oz to improve how care is financed and delivered across Medicare, Medicaid and the Children’s Health Insurance Program, and the Health Insurance Marketplace.
Read the full press release.
ICD-10 & Other Coding Revisions to National Coverage Determinations: January 2026 Update
Learn about new or deleted ICD-10 diagnosis codes effective January 1, 2026. See update 1 of 2 (PDF) and 2 of 2 (PDF).
CMS Announces Changes to Achieving Healthcare Efficiency through Accountable Design (AHEAD) Model to Improve Quality, Promote Transparency, and Manage Costs
What’s new: The CMS Innovation Center announced new policy and operational changes, as well as a new end date, to the AHEAD Model to help states achieve their total cost of care (TCOC) targets, while advancing the Center’s commitment to promote choice and competition, increase prevention, empower patients, and protect taxpayer dollars.
Why it matters: Participating states now have more tools to manage Medicare costs (designed to support sustainable growth) and improve quality of care and population health outcomes.
What to expect: Changes will be implemented across all cohorts beginning in January 2026. AHEAD’s end date for all cohorts is now December 31, 2035.
The big picture: Changes made to the model will help to advance the CMS Innovation Center’s strategic pillars of: 1) choice and competition, with states implementing at least two policies focused on promoting choice and competition in their health care markets and 2) prevention, with a new Population Health Accountability Plan focused on preventive care, including chronic disease prevention.
Additional details: CMS is also introducing payment reforms through AHEAD for patients with Original Medicare and establishing new transparency requirements around TCOC and primary care investment targets. For the first time ever, AHEAD will bring total cost of care accountability to all Original Medicare beneficiaries in AHEAD regions through geographic attribution of beneficiaries not attributed to other CMS accountable care organization programs. This novel framework will offer risk-bearing Geographic Entities additional tools and enhanced flexibilities to improve health outcomes and lower spending for their patients while receiving shared payments (or losses) through two-sided risk arrangements. In return, patients may receive additional beneficiary incentives while enjoying existing protections under the Original Medicare program.
The AHEAD Model is a state total cost of care (TCOC) model that seeks to drive state and regional health care transformation and multi-payer alignment, with the goal of improving the total health of a state population and lowering costs. Under a TCOC approach, a participating state uses its authority to assume responsibility for managing health care quality and costs across all payers, including Medicare, Medicaid, and private coverage. States also assume responsibility for ensuring health providers in their state deliver high-quality care, improve population health, offer greater care coordination, and promote healthier living for all people participating in the model. The AHEAD Model provides participating states with funding and other tools to address rising health care costs and improve health outcomes.
Find out more:
HHS Announces Crackdown on Health Data Blocking
HHS announced it will increase resources dedicated to curbing the harmful practice of information blocking. HHS will take an active enforcement against health care entities that restrict patients’ engagement in their care by blocking the access, exchange, and use of electronic health information.
The 21st Century Cures Act of 2016 authorized the Office of the Assistant Secretary for Technology Policy/Office of the National Coordinator for Health IT (ASTP/ONC) and HHS Office of Inspector General (OIG)are to take enforcement actions to hold those who block patient information accountable and to prevent future violations. As a result, ASTP, the principal federal entity charged with coordination of nationwide efforts to implement and use the most advanced health information technology, and the OIG, the primary investigative division of HHS, will play leading roles in this initiative.
HHS Agrees to Restore Health Websites and Data
Federal officials have agreed to restore health- and science-related webpages and data under to a lawsuit settlement with doctors’ groups and other organizations who sued. The settlement was announced this week by the lead plaintiffs in the case, the Washington State Medical Association. HHS has agreed to restore more than 100 websites and resources to the state they were in.
HHS Expands Access to Affordable Health Insurance
HHS announced today it is implementing important measures to expand access to more affordable catastrophic health coverage through HHS’ new hardship exemption guidance. This guidance streamlines access to more affordable catastrophic coverage for consumers who are ineligible for advance payments of the premium tax credit (APTC) or cost-sharing reductions (CSRs).
HHS is also simplifying the process by streamlining the review of paper applications to reduce the administrative burden on consumers. This change will make it easier for individuals experiencing hardship and seeking a catastrophic plan to access the full range of catastrophic coverage options available to them.
HHS’ hardship exemption guidance for catastrophic coverage can be viewed on CMS.gov at: https://www.cms.gov/marketplace/resources/regulations-guidance#Health-Insurance-Marketplaces
A fact sheet on HHS’ hardship exemption guidance for catastrophic coverage is available at: https://www.cms.gov/newsroom/fact-sheets/expanding-access-health-insurance-consumers-gain-access-catastrophic-health-insurance-plans-2026
Educational Opportunities
Combating Medicare Parts C & D Fraud, Waste & Abuse — Revised
CMS updated this web-based training course, including:
- Penalties for violating specific laws
- Real-world fraud, waste, and abuse examples
CMS Resources
Improve Your Search Results for CMS Content
If you’re using a search engine to find information on CMS.gov, include “CMS” in your search term to get the best results. If you recently visited a CMS webpage, you may need to refresh your browser to see the latest content.
