Compliance Monitor (1/26/26)
Your source for federal updates – by Jennifer Kennedy
January 2026 Compliance Activity
| Medicare Care Compare Refresh Home health quality scores are publicly reported on the Care Compare website and updated on a quarterly basis | Medicare Care Compare Information about home health public reporting dates |
| CMS Home Health Payment Update Rule (Final) Final payment update rates and provisions of the final rule are effective for home health, home infusion therapy, and DMEPOS providers January 1, 2026 | Final rule in the Federal Register |
| Telehealth extension – Hospice Section 6208 of the Continuing Appropriations, Agriculture, Legislative Branch, Military Construction and Veterans Affairs, and Extensions Act, 2026 extended the use of telehealth by a hospice physician or hospice nurse practitioner to conduct a face-to-face encounter for the sole purpose of hospice recertification. This extension is through January 30, 2026. This constitutes a temporary change in the regulations at 42 CFR 418.22(a)(4)(ii). | CMS Hospice Center |
| Telehealth extension – Home Health CMS home health telehealth flexibilities (like receiving care at home and waiving geographic restrictions for some services) have been extended through January 30, 2026 | CMS Telehealth Policy Updates |
Top Items
February 2026 Deadline: HIPAA Covered Entities Handling Substance Use Disorder Records Must Update Notices of Privacy Practices
- HIPAA covered entities that process SUD records under 42 CFR Part 2 must update their Notice of Privacy Practices (NPP) by February 16, 2026.
- This is required due to the HHS final rule aligning 42 CFR Part 2 with the HIPAA Privacy Rule, which expands allowed uses while maintaining confidentiality for SUD information.
- The rule applies to any covered entity whose systems handle Part 2 records, even if they are not an SUD treatment program.
- Covered entities should begin reviewing privacy notices and data practices now to reduce compliance and enforcement risk.
Providers & Suppliers: CMS Has Authority to Conduct Enrollment Site Visits
CMS conducts authorized enrollment site visits to verify operational status. Site visit inspectors carry a photo ID and CMS-issued letter of authorization that you may review but not retain or copy.
Starting January 3, 2026, 2 new site verification service contractors will conduct these visits:
- East: Arch Systems, LLC
- West: Signature Consulting Group
Until February 14, 2026, outgoing contractors may continue performing site visits:
- East: Palmetto GBA and its subcontractors:
- Overland Solutions, Inc., an affiliate of EXL
- Information Discovery Services
- Compliance Review, Inc.
- National Creditors Connection, Inc.
- West: Deloitte Consulting, LLP and its subcontractors:
- Nationwide Management Services, Inc.
- CSI Companies, Inc.
- Arthur Lawrence Management, LLC
- Computer Evidence Specialists, LLC
Hospice/Palliative Care Provider Updates
Important Updates on the Hospice Quality Reporting Program (HQRP)
The latest outreach communication can be found on the HQRP Requirements and Best Practices webpage.
Home Health Provider Updates
New and Updated Resources Available for the Expanded HHVBP Model
Several new and updated resources are now available on the Expanded Home Health Value-Based Purchasing (HHVBP) Model webpage.
New Resources
Updated Resources
Performance Year Results
CMS has also posted results from the second performance year of the expanded HHVBP Model (CY 2024) in the Provider Data Catalog (PDC).
Public Reporting January 2026 Refresh of HH QRP Data – Now Available
The January 2026 refresh of the HH QRP is now available on the Compare Tool on Medicare.gov and Provider Data Catalog (PDC).
The data are based on quality assessment data submitted by HHAs to Centers for Medicare & Medicaid Services (CMS) from Quarter 2, 2024 through Quarter 1, 2025. The data for the claims-based measures will display data from Quarter 1, 2023 through Quarter 4, 2024 for the Discharge to Community and Medicare Spending Per Beneficiary measures, Quarter 1, 2022 through Quarter 4, 2024 for the Potentially Preventable 30-Day Post-Discharge Readmission measure, and Quarter 1, 2024 through Quarter 4, 2024 for the Home Health Within-Stay Potentially Preventable Hospitalization measure. Additionally, the data for the HHCAHPS measures will display data from Quarter 3, 2024 through Quarter 2, 2025.
The January 2026 refresh includes one new OASIS-based measure, COVID-19 Vaccine: Percent of Patients Who Are Up to Date.
Please visit the Compare Tool on Medicare.gov and PDC to view the updated quality data. For questions about HH QRP Public Reporting, please email homehealthqualityquestions@cms.hhs.gov.
Preview Reports and Star Rating Preview Reports for the April 2026 Refresh of HH QRP Data – NOW AVAILABLE IN iQIES
REMINDER: The HHA Provider Preview Reports have been updated and are now available. 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 April 2026 refresh.
Data contained within the Provider Preview Reports are based on quality assessment data submitted by HHAs from Quarter 3, 2024 through Quarter 2, 2025. The data for the claims-based measures will display data from Quarter 1, 2023 through Quarter 4, 2024 for the Discharge to Community and Medicare Spending Per Beneficiary measures, Quarter 1, 2022 through Quarter 4, 2024 for the Potentially Preventable 30-Day Post-Discharge Readmission measure, and Quarter 1, 2024 through Quarter 4, 2024 for the Home Health Within-Stay Potentially Preventable Hospitalization measure. Additionally, the data for the HHCAHPS measures will display data from Quarter 4, 2024 through Quarter 3, 2025.
The Preview Reports for the April 2026 will no longer include one OASIS-based measure, COVID-19 Vaccine: Percent of Patients Who Are Up to Date.
Providers have until February 9, 2026, to review their performance data. Only updates/corrections to the underlying assessment data before the final data submission deadline will be reflected in the publicly reported data on Medicare.gov. If a provider updates assessment data after the final data submission deadline, the updated data will only be reflected in the Facility-Level Quality Measure (QM) report and Patient-Level QM report. Updates submitted after the final data submission deadline will not be reflected in the Provider Preview Reports or on Medicare.gov. However, providers can request a CMS review of their data during the preview period if they believe the displayed quality measure scores within their Provider Preview Reports are inaccurate.
For questions related to accessing your facility’s Provider Preview Report, please contact the iQIES Service Center by email at iqies@cms.hhs.gov or call 1-800-339-9313. For questions about HHA Quality Reporting Program (QRP) Public Reporting, please email homehealthqualityquestions@cms.hhs.gov.
Preliminary January 2026 Interim Performance Reports (IPRs) are Available in iQIES
The Preliminary January 2026 IPRs for the expanded HHVBP Model have been published in the Internet Quality Improvement and Evaluation System (iQIES).
The quarterly IPRs provide home health agencies (HHAs) with the cohort assignment, performance year measure data for the 12 most recent months, and the interim Total Performance Score (TPS). Using the IPRs, an HHA can assess and track their performance relative to peers in their respective cohort throughout the expanded Model performance year. Note that the CY 2025 measure set is reported as of the October 2025 IPRs. Please refer to the Expanded HHVBP Model Guide, Section 4.2, for a list of the CY 2025 applicable measures.
An HHA receives a January 2026 IPR if the HHA:
- Was Medicare certified prior to January 1, 2024, and
- Meets the minimum threshold of data for at least one (1) quality measure in the quarterly reporting period for the performance year shown in Exhibit 1.
Exhibit 1: January 2026 IPR quality measure performance scores time periods for each measure category
| Measure Category | Time Period | Minimum Data Threshold |
| OASIS-based | Jul 1, 2024 – Sep 30, 2025 | 20 home health quality episodes |
| Claims-based | DTC-PAC: Jul 1, 2023 – Jun 30, 2025 PPH: Jul 1, 2024 – Jun 30, 2025 | 20 home health stays |
| HHCAHPS Survey-based* | Jul 1, 2024 – Jun 30, 2025 | 40 completed surveys |
As outlined in the CY 2026 Home Health (HH) Prospective Payment System (PPS) Final Rule, there are changes to the expanded HHVBP Model measure set starting with CY 2026 (referred to as the “CY 2026 measure set”). The October 2026 IPRs will be the first IPRs to generate improvement, achievement, and care points based on the CY 2026 applicable measure set. To help HHAs get ready for this change, CMS has started providing a preview of HHAs’ performance on the CY 2026 measure set. Specifically, starting with the October 2025 IPRs, achievement thresholds (AT) and benchmarks (BM) (see “CY 2026 AT and BM” tab) and the HHA’s improvement thresholds for the CY 2026 measure set are available to HHAs in each IPR.
Submitting an IPR Recalculation Request
There are two (2) versions of the quarterly IPRs: a Preliminary IPR and a Final IPR. The Preliminary IPR provides an HHA with an opportunity to submit a recalculation request for applicable measures and interim performance scores if the agency believes there is evidence of a discrepancy in the calculation. Please note, the recalculation request does not apply to errors in data submission since submission requirements for the expanded Model align with current Code of Federal Regulations (CFRs).
To dispute the calculation of the performance scores in the Preliminary IPR, an HHA must submit a recalculation request within 15 calendar days after publication of the Preliminary IPR. For the January 2026 IPR, HHAs must submit a recalculation request by February 6, 2026. The Final IPR will reflect any changes resulting from an approved recalculation request.
HHAs may submit requests for recalculation by emailing hhvbp_recalculation_requests@abtglobal.com. Recalculation requests must contain the following information, as cited in the CY 2022 HH PPS final rule (p. 62331) and CFR §484.375:
- The provider’s name, address associated with the services delivered, and CCN.
- The basis for requesting recalculation to include the specific data that the HHA believes is inaccurate or the calculation the HHA believes is incorrect.
- Contact information for a person at the HHA with whom CMS or its agent can communicate about this request, including name, email address, telephone number, and mailing address (must include physical address, not just a post office box).
- A copy of any supporting documentation, not containing PHI or PII, the HHA wishes to submit in electronic form.
Note: When submitting recalculation and reconsideration requests:
- CMS asks HHAs to only include one CCN per request.
- If you are submitting a recalculation request due to a suspected discrepancy between measure values reported in your IPR and measure values calculated internally or by your HHA’s vendor, please consider providing a copy of the internal/vendor report used to generate the internal data to assist CMS with investigating your HHA’s request.
- If possible, confirm whether 1) your internal data are risk-adjusted and 2) the data source used to generate your internal measure values (e.g., OASIS data, claims data).
- Please do not include any PHI/PII.
These instructions are also available on the Expanded HHVBP Model webpage, under “Model Reports.”
Remote Patient Monitoring: Use & Bill Correctly
In a report, the Office of the Inspector General recommended additional oversight of remote patient monitoring in Medicare. About 43% of enrollees who received remote patient monitoring didn’t receive all 3 components, raising questions about whether it’s being used as intended.
Learn how to correctly use and bill for remote patient monitoring:
- Remote Patient Monitoring webpage
- Telehealth & Remote Monitoring booklet
DMEPOS Updates
DMEPOS: Updated List of Items Potentially Subject to Conditions of Payment
CMS added 18 items to the Master List of DMEPOS Items Potentially Subject to Conditions of Payment. We didn’t remove any items.
If CMS selects these items for face-to-face encounter, written order prior to delivery, or prior authorization, you may be required to do one or both:
- Meet with your patient and give them a written order before delivering the item
- Ask your Medicare Administrative Contractor to authorize the item in advance
More Information:
- Required Face-to-Face Encounter and Written Order Prior to Delivery List (PDF): Added 8 new oxygen items
- Required Prior Authorization List (PDF): Added 5 new orthoses and 2 pneumatic compression device items
All Providers Updates
Now Posted: December 11 Webcast Replay and Slides on Bridging Patient-Reported Experience and Outcomes in Healthcare
This webcast explored how integrating Patient-Reported Experience Measures (PREMs) and Patient-Reported Outcome Measures (PROMs) offers a comprehensive view of patient care and delivers actionable insights that support quality improvement. Experts from AHRQ’s Consumer Assessment of Healthcare Providers and Systems (CAHPS®) program shared practical approaches, real-world examples, and emerging best practices for using these tools together to strengthen patient-centered care.
Select to access the recording of the webcast and download related materials
At a Glance: Fall 2025 Semiannual Report to Congress
The HHS-OIG released the Fall 2025 Semiannual Report to Congress, summarizing its activities and accomplishments during the last six months, April 1, 2025 – September 30, 2025.
Educational Opportunities
LEAD (Long-term Enhancing ACO Design) Model Overview Webinar
(CMS) will host a webinar on Thursday, January 29, 2026, about the LEAD Model, including model goals, participation options, eligibility and payment methodology. The LEAD Model team will also provide more information on the application process, timeline and resources.
Session information and the registration link are below. Please submit questions in advance via the registration form and forward event details to colleagues who may be interested in learning more about the LEAD Model.
LEAD builds upon the CMS Innovation Center’s earlier accountable care work and utilizes improved benchmarking to appeal to a broader mix of health care providers, including those with specialized patient populations and those new to ACOs. With a 10-year performance period — the longest ever tested by the CMS Innovation Center — LEAD offers a pathway toward sustainable long-term benchmarks and savings. It also focuses on better serving coordinated care for high-needs patients, such as those dually eligible for Medicare and Medicaid, and those who are homebound or home-limited.
LEAD Model Overview Webinar Date and Time:
Thursday, January 29, 2026, 2:00 – 3:00 pm ET
Register to attend here:
https://deloitte.zoom.us/webinar/register/WN_1AZybXFxReqjDMVKTjEpng#/registration
Following the event, presentation materials will be available on the LEAD Model webpage.
You may contact the LEAD Help Desk at LEAD@cms.hhs.gov with questions. To stay up to date on upcoming model announcements, events, and resources, join our LEAD listserv by visiting the LEAD Model webpage.
CCSQ Quarterly Stakeholder Webinar – February 4
Wednesday, February 4 from 3–4 pm ET
Register for this webinar.
You’re invited to join Dr. Dora Hughes, Chief Medical Officer of CMS and Director of the Center for Clinical Standards and Quality (CCSQ), and the CCSQ leadership team for an engaging update on our work to strengthen health care quality, safety, and coverage. Hear the latest on recent policy developments and how these efforts are accelerating progress toward improving care and outcomes for beneficiaries in Medicare, Medicaid, and the Marketplace.
2026 CMS Burden Reduction Conference!
The Centers for Medicare & Medicaid Services (CMS) invites you to join us on Wednesday, February 25, 2026, from 9:00 AM to 1:00 PM ET.
Building on insights and successes from past conferences, this year’s event will convene CMS leadership, clinicians, and healthcare stakeholders to explore the latest efforts to reduce administrative burden, improve care delivery, and advance the use of technology across the healthcare ecosystem. The conference will feature a keynote speech from CMS Administrator Dr. Mehmet Oz, along with panel discussions and sessions focused on practical approaches to reduce administrative burden.
Please register for the virtual event, as we have reached our limit on in-person registration. Upon registering, you may add your name to the in-person waitlist, and we will notify you if space becomes available to join in person leading up to the conference. Additional details — including an agenda with session topics — are available on the Conference webpage.
For questions or additional information, please email CMSBurdenReductionConference@rippleeffect.com . Be sure to add this event to your calendar after registering.
Register for the CMS Webinar on January 21, 2026 for the Digital Quality Measure (dQM) Public Comment Period
HL7 Fast Healthcare Interoperability Resources® (FHIR®) is the next-generation standard for electronic healthcare data exchange, supporting improved interoperability across clinical settings. The Centers for Medicare & Medicaid Services (CMS) is exploring the transition of electronic clinical quality measures (eCQMs) to digital quality measures (dQMs) using FHIR-based standards to enable standardized, electronic data sharing.
As CMS seeks public comment on draft dQMs, you are invited you to a webinar highlighting the transition to FHIR based standards and what to expect for the dQM Public Comment Period.
When: January 21, 2026
Who Should Attend:
Health IT developer/vendor, measure developers, implementers, and others interested in the transition to FHIR quality measurement. This webinar assumes the attendees have prior knowledge of Health Level Seven International® and FHIR terminology.
Webinar Topics Will Include:
- Overview of the transition to dQMs using FHIR
- Introduction to the Measure Authoring Development Integrated Environment (MADiE)
- Comparison of dQM and eCQM artifacts
- Test case examples
- CMS and CDC Hypoglycemic Reporting
- Details on the dQM public comment period
- Date: January 21, 2026
- Time: 2pm ET
Additional Information:
- Visit the FHIR Education and dQM pages on the Electronic Clinical Quality Improvement (eCQI) Resource Center for educational materials.
- Submit FHIR-related questions to: ecqi@lantanagroup.com.
- Learn more about electronic clinical quality measure standards on the eCQI Resource Center.
2026 ASTP Annual Meeting Registration Is Filling Up: Register Today
Registration is open but limited for the 2026 ASTP Annual Meeting! Register to secure your seat on February 11-12 in Washington, DC for two days of conversation, learning, and networking.
Register today →
On the main stage, we’ll discuss the latest TEFCA™ developments, HHS’s commitment to improving prior authorization, artificial intelligence in health care settings, and the newest innovations in digital health. Check out breakout sessions about information blocking (including an information blocking bootcamp!), TEFCA, the latest data analysis from ASTP, USCDI, and more.
For those who are unable to attend in person, the main stage sessions will be live-streamed. A room block at the Omni Shoreham is available on a first-come, first-served basis until January 19, 2026 so book your room today.
Reserve a hotel room →