
Compliance Monitor (09/29/2025)
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 |
Acute Hospital Care at Home program Extension expires Sep 30, 2025 | The Acute Hospital Care at Home program, which allows hospitals to provide hospital-level care in patients’ homes, will expire Sept. 30 unless Congress extends authorization for the CMS to grant waivers. |
Hospice Item Set (HIS) September 30, 2025 | Last HIS admission and discharge records are submitted |
CMS HQRP Compliance Reconsideration Results | Reconsideration results delivered in August/ September |
OCTOBER 2025 PREVIEW: | |
FY 2026 Hospice Payment Update final rule October 1, 2025 | Provisions of this rule are effective https://www.govinfo.gov/content/pkg/FR-2025-08-05/pdf/2025-14782.pdf Review the CHAP summary of the final rule |
Hospice HOPE October 1, 2025 | Implementation of the hospice HOPE assessment tool |
Top Items
The Federal Register posted a 30-day notice that authorizes the HHS Secretary to “develop or demonstrate improved methods for the investigation and prosecution of fraud in the provision of care or services under the health programs established by the Social Security Act (the Act).” Pursuant to this authority, the CMS seeks to develop and implement a Medicare demonstration project, which CMS believes will help assist in developing improved procedures for the identification, investigation, and prosecution of Medicare fraud occurring among Home Health Agencies (HHA) providing services to Medicare beneficiaries.
This revised demonstration helps assist in developing improved procedures for the identification, investigation, and prosecution of potential Medicare fraud. The demonstration helps make sure that payments for home health services are appropriate through either pre-claim or post payment review, thereby working towards the prevention and identification of potential fraud, waste, and abuse; the protection of Medicare Trust Funds from improper payments; and the reduction of Medicare appeals. CMS has implemented the demonstration in Illinois, Ohio, North Carolina, Florida, and Texas with the option to expand to other states in the Palmetto/JM jurisdiction.
Providers in the demonstration states may participate in either 100 percent pre-claim review or 100 percent post payment review. These providers will continue to be subject to a review method until the HHA reaches the target affirmation or claim approval rate. Once an HHA reaches the target pre-claim review affirmation or post-payment review claim approval rate, it may choose to be relieved from claim reviews, except for a spot check of their claims to ensure continued compliance.
Comments on the collection(s) of information must be received by the OMB desk officer by October 25, 2025.
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.
Hospice/Palliative Care Provider Updates
The Hospice Outcomes and Patient Evaluation Tool Launch
On October 1, 2025, the Hospice Outcomes and Patient Evaluation (HOPE) tool will replace the current Hospice Item Set (HIS). HOPE includes a combination of existing HIS items, revised, and new items. Once implemented, all HOPE records will be submitted to CMS via the Internet Quality Improvement and Evaluation System (iQIES).
Final materials, resources, and trainings are available to assist providers and staff with a successful implementation of HOPE. These are posted on CMS’HQRP website and include:
- The HOPE Guidance Manual v1.01, corresponding items sets, and the change table on the HOPE
- HOPE Data Specs and Vendor training on the HOPE Technical Information
- HOPE Training materials on the HQRP Training and Education Library page:
- Course 1: Didactic Recorded Training Series
- Course 2: Coding Workshop
- HOPE Implementation Frequently Asked Questions (FAQs)
- HOPE Tool Web-Based Training
All of these resources can be accessed either from direct links or in the Downloads section on the webpages listed above.
For additional questions about HOPE implementation or the HOPE tool, email: HospiceQualityQuestions@cms.hhs.gov.
UPDATED RESOURCES AVAILABLE: HQRP: Achieving a Full Annual Payment Update (APU) Training
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/x49Xtn5GpSc
- 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
OIG Report: Texas Did Not Calculate or Collect Hospice Cap Overpayments Totaling $10.5 Million (A-06-24-09001)
This audit determined whether the State of Texas correctly calculated and collected hospice cap overpayments and refunded the Federal share of those overpayments to the Federal Government. OIG found Texas overpaid $10.5 million ($6.9 million Federal share) to 174 hospices (36 percent of hospices that received payments) for services provided during Federal Fiscal Years 2020 through 2022 because it did not have any policies and procedures related to calculating and collecting the hospice cap overpayments. Texas did not calculate these cap overpayments; therefore, it did not collect them or return the related Federal share.
Hospice Payments: FY 2026 Update
Learn about updates (PDF) effective October 1, 2025:
- Payment rates
- Inpatient and aggregate caps
- Wage index
OIG Report- Texas Did Not Calculate or Collect Hospice Cap Overpayments Totaling $10.5 Million (A-06-24-09001)
Texas overpaid $10.5 million ($6.9 million Federal share) to 174 hospices (36 percent of hospices that received payments) for services provided during Federal fiscal years 2020 through 2022 because it did not have any policies and procedures related to calculating and collecting the hospice cap overpayments. Texas did not calculate these cap overpayments; therefore, it did not collect them or return the related Federal share.
DME Provider Updates
Manual Wheelchairs: Prevent Claim Denials
In 2023, the improper payment rate for manual wheelchairs was 42.6%, with a projected improper payment amount of $42.8 million (see 2023 Medicare Fee-for-Service Supplemental Improper Payment Data (PDF)). Learn how to bill correctly for these services. Review the Manual Wheelchairs provider compliance tip for more information, including:
- Billing codes
- Denial reasons and how to prevent them
- Documentation requirements
DMEPOS Fee Schedule: October 2025 Quarterly Update
Learn about updates (PDF) effective October 1, 2025:
- Added and deleted HCPCS codes
- Corrected 2024 deflation factors
All Providers Updates
CMS Issues Guidance to Strengthen Oversight of Medicaid State Directed Payments
CMS is issuing preliminary guidance for states regarding the implementation of new federal payment limits for State Directed Payments (SDPs) in Medicaid managed care. Providing this guidance now, while CMS works to issue a final rule, allows states additional time to plan their efforts to meet the requirements laid out in the One Big Beautiful Bill Act. The letter sent today provides states with information on the reduced payment, details on eligibility for a temporary grandfather period, and additional next steps. By implementing the new required safeguards effective for rating periods beginning on or after July 4, 2025, CMS aims to ensure Medicaid resources are directed appropriately to strengthen program integrity and protect patient care.
CMS Launches Landmark $50 Billion Rural Health Transformation Program
CMS unveiled details on how states can apply to receive funding from the $50 billion Rural Health Transformation Program created under the Working Families Tax Cuts Act to strengthen health care across rural America. This unprecedented investment is designed to empower states to transform the existing rural health care infrastructure and build sustainable health care systems that expand access, enhance quality of care, and improve outcomes for patients. The Rural Health Transformation Program invites all 50 states to apply for funding to address each state’s specific rural health challenges. The Program enables states to reimagine care delivery and develop innovative, enduring, state-driven solutions to tackle the root causes of poor health outcomes specific to rural America.
The deadline for states to apply is November 5, 2025. There is only one opportunity to apply for funding and one application period for this program. CMS will announce awardees by December 31, 2025, and will partner with states over the program period to ensure strong oversight and successful implementation of initiatives with lasting impact.
The Trump Administration announced its Unified Agenda of Regulatory and Deregulatory Actions, which provides the American people with a transparent look at regulations being considered by the Administration and ensures the public is engaged throughout the process.
Including nearly 150 proposals under the U.S. Department of Labor’s jurisdiction, the agenda reflects President Trump’s ongoing commitment to protect workers, support business growth, and ultimately put American workers and businesses first.
Fraud, Waste & Abuse – Duplicate Enrollment in Medicaid & Marketplace: New Fast Facts
CMS released new Fast Facts (PDF) about the ways we’re making sure people aren’t enrolled in more than one state Medicaid program or enrolled in both Medicaid and a Marketplace plan. Duplicate enrollment wastes taxpayer dollars and puts added strain on an already burdened health care system. Individuals identified with potential duplicate enrollment may need to take action to ensure they’re enrolled only in the program they’re eligible for.
We’re taking action to safeguard taxpayer funds and enhance the public’s confidence in these vital programs. Visit CMS.gov/fraud for more fast facts and resources.
Cognitive Assessment: Recommend Medicare-Covered Services for Your Patients
Your patients may tell you they’re having trouble remembering things, concentrating, or making everyday decisions. Their Medicare Summary Notice highlights that Medicare Part B covers a visit with their doctor or a specialist to talk about it and do an exam.
Recommend appropriate Medicare services, including:
Information for patients:
Justice Department Expands Health Care Fraud Unit to Target Health Care Fraud in Massachusetts
The Justice Department’s Criminal Division today announced the expansion of its Health Care Fraud Unit’s New England Strike Force to the District of Massachusetts. This expansion brings enhanced federal enforcement resources to one of the nation’s most significant health care and life sciences hubs. As part of the expansion, the New England Strike Force, which was launched in June 2022, will coordinate closely with the U.S. Attorney’s Office’s Health Care Fraud Unit, led by Chief Mackenzie Queenin. In addition to the FBI, HHS-OIG and FDA, the Strike Force will partner with the Drug Enforcement Administration, Homeland Security Investigations, the Department of Veterans Affairs Office of Inspector General, IRS Criminal Investigation, and key state agencies, including the Medicaid Fraud Control Unit of Massachusetts and the Insurance Fraud Bureau of Massachusetts.
ACIP Recommends COVID-19 Immunization Based on Individual Decision-making
CDC) Advisory Committee on Immunization Practices (ACIP) today unanimously recommended that vaccination for COVID-19 be determined by individual decision-making. ACIP’s recommendation applies to all individuals six months and older. It includes an emphasis that the risk-benefit of vaccination in individuals under age 65 is most favorable for those who are at an increased risk for severe COVID-19 and lowest for individuals who are not at an increased risk, according to the CDC list of COVID-19 risk factors.
Educational Opportunity
Register for the CAHPS End-of-Life Care Survey Webcast on October 16, 2025
Date: Thursday, October 16, 2025
Time: 1-2 p.m. ET
Register for this free, one-hour webcast introducing AHRQ’s new Consumer Assessment of Healthcare Providers and Systems (CAHPS®) End-of-Life Care Survey. Join leading experts as they discuss why the survey was developed, how it was tested, and best practices for successful implementation. Kaiser Permanente will share lessons learned from field testing the survey in their end-of-life care programs.
CMS Resource
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Emergency Preparedness Resources
The ASPR Technical Resources, Assistance Center, and Information Exchange (TRACIE) was created to meet the information and technical assistance needs of regional ASPR staff, healthcare coalitions, Medical Reserve Corps (MRC) units, healthcare entities, healthcare providers, emergency managers, public health practitioners, and others working in disaster medicine, healthcare system preparedness, and public health emergency preparedness.
Recent featured resources include:
- Hurricanes Resource Page
- New Data Sources for Hazard Vulnerability Assessments Resource Page
- Recently updated Tips for Retaining and Caring for Staff after a Disaster and Healthcare Facility Evacuation/Sheltering and Hazard Vulnerability/Risk Assessment
- Topic Collections; and our Utility Failures in Health Care Toolkit