Compliance Monitor (10/13/2025)

Compliance Monitor (10/13/2025)

Your source for federal updates.

October 2025 Compliance Activity 

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  
Pre-pandemic practices for HHA certification and hospice F2F in place 
October 1, 2025 		Home health providers
– The allowance for telehealth visits to certify a patient for home health expired 9/30/2025 Hospice providers
– The allowance for telehealth visits to complete a face-to-face visit for recertification expired 9/30/2025  
Hospice HOPE 
October 1, 2025 		Implementation of the hospice HOPE assessment tool  
Comments on the collection(s) of information must be received by the OMB desk officer by October 25, 2025.  Extension of a currently approved collection; Title of Information Collection: Review Choice Demonstration for Home Health Services  

Top Items 

Federal Government Shutdown 

The federal government has been shut down since 10/1/2025.  Communication from CMS and other federal entities is limited or suspended until it reopens. 

CHAP posted two CMS memos related to the shutdown which can be viewed at 2025 Government Shutdown Resources for Providers 

Home Health Provider Updates 

Expanded HHVBP Model: Preliminary CY 2025 Annual Performance Reports (APRs) are Available in iQIES  

Preliminary CY 2025 Annual Performance Reports (APRs) are Available in iQIES 

The Preliminary CY 2025 Annual Performance Reports (CY 2025 APRs) for the expanded HHVBP Model have been published in the Internet Quality Improvement and Evaluation System (iQIES). 

Important note: As a result of the recalculation request process, CMS adjusted the CY 2025 APR data used for HHAs in the larger-volume cohort. This adjustment resulted in a slightly higher Adjusted Payment Percentage (APP) for some HHAs in the larger-volume cohort. If your HHA is in the larger-volume cohort, please compare your HHA’s APP in the Preview CY 2025 APR to the APP reported in the Preliminary CY 2025 APR to see if your HHA was impacted. If your HHA is in the smaller-volume cohort, no changes to your HHA’s APP were made. 

The CY 2025 APRs provide the HHA’s APP based on performance in CY 2024, the performance year, which will be applied to Medicare Fee-for-Service (FFS) claims with through dates in the payment year, CY 2026. In addition, the CY 2025 APRs provide information related to HHA performance on key metrics that feed into the HHA’s APP, including performance measure scores, Improvement Points, Achievement Points, Care Points, and the Total Performance Score (TPS). 

An HHA receives a CY 2025 APR if the HHA: 

  • Was Medicare-certified prior to January 1, 2023, and 
  • Had sufficient data for at least five quality measures to calculate a TPS and APP. 

Exhibit 1: CY 2025 APR quality measure performance scores time periods for each measure category  

Measure Category Time Period Minimum Threshold 
OASIS-based January 1 – December 31, 2024        20 home health quality episodes 
Claims-based January 1 – December 31, 2024 20 home health stays 
HHCAHPS Survey-based*    January 1 – December 31, 2024 40 completed surveys 

* Not included in the TPS calculation for HHAs in the smaller-volume cohort. 

Note: APRs are only available to HHAs through iQIES. 

Below is a list of the calendar years that are relevant to the “CY 2025 APR”, namely the baseline year, performance year, publication year, and payment year. 

  • The baseline year is CY 2022 and is used to calculate quality measure-specific achievement thresholds and benchmarks. CY 2022 and CY 2023 are used to calculate improvement thresholds depending on an HHA’s initial Medicare certification date and availability of sufficient data in the baseline years. 
  • CY 2024 is the performance year, and HHA performance in this calendar year is measured against 12 quality measures relative to performance of HHAs in each cohort. 
  • The publication year of the “CY 2025 APR” is CY 2025. 
  • CY 2026 is the payment year. That means that the HHA’s APP ranging from minus 5% to plus 5% is applied to Medicare Fee-for-Service (FFS) claims with through dates in CY 2026. 

Accessing APRs 

APRs are available via iQIES in the “HHA Provider Preview Reports” folder, by the CMS Certification number (CCN) assigned to the HHA. If your organization has more than one (1) CCN, then a report will be available for each CCN. Only iQIES users authorized to view an HHA’s reports can access expanded HHVBP Model reports. For assistance with downloading your HHA’s APR, please contact the iQIES Service Center at 1-800-339-9313, Monday through Friday, 8:00 AM-8:00 PM ET, or by email (iqies@cms.hhs.gov).  To create a ticket online or track an existing ticket, please go to CCSQ Support Central. 

  1. Log into iQIES at https://iqies.cms.gov/. 
  1. Select the My Reports option from the Reports menu. 
  1. From the My Reports page, select the HHA Provider Preview Reports folder. The folders and reports on the My Reports page are listed in alphabetical order. Thus, users may need to utilize the “page forward” functionality at the bottom of the webpage to advance to the page where the HHA Provider Preview Reports folder is located. Alternatively, users may change the default number of rows that display on the webpage from 10 to a larger number to view the larger list of folders. Note: Files in the HHA Provider Preview Reports folder are listed in descending order (i.e., in the order of the newest reports to the oldest). 
  1. Select the HHVBP report file, and the contents of the file will display.  

Instructions on how to access the APRs are also available on the Expanded HHVBP Model webpage, under “Model Reports.” 

The Appeals Process 

There are three (3) versions of the APRs: a Preview APR, a Preliminary APR, and a Final APR. 

  1. The “Preview APRs” were published on August 21, 2025. HHAs had 15 calendar days to submit a recalculation request if they found evidence of an error in their report. The deadline for submitting a recalculation request for the CY 2025 APRs was September 5, 2025. 
  1. The “Preliminary APRs” were published on September 30, 2025 and reflect any changes resulting from an approved recalculation request.  
  • HHAs will have 15 calendar days from the publication of the “Preliminary APRs” to submit a reconsideration request if they submitted a recalculation request and are not in agreement with the recalculation request decision. Note: HHAs that did not submit a recalculation request are not eligible to submit a reconsideration request. The deadline for submitting a reconsideration request for the CY 2025 APRs is October 15, 2025.  
  • HHAs will also have 7 calendar days from the notification of the reconsideration request decision to submit a request for Administrator review if they submitted a reconsideration request and are not in agreement with the reconsideration request decision. Note: HHAs that did not submit a reconsideration request are not eligible to submit a request for Administrator review. The deadline for submitting a request for Administrator review for the CY 2025 APRs is November 6, 2025. 
  1. CMS makes the “Final APRs” available after all recalculation requests, reconsideration requests, and requests for Administrator review are processed, and no later than 30 calendar days before the payment adjustment takes effect on January 1, 2026. 

HHAs that submitted a recalculation request by September 5, 2025 received instructions on how to submit a reconsideration request as part of the email notifying them of the outcome of the recalculation request decision.