Compliance Monitor (11/21/2025)

Your source for federal updates 

November 2025 Compliance Activity 

Medicare Care Compare Refresh  Home health quality scores are publicly reported on the Care Compare website and updated on a quarterly basis.    November 2025 (usually distributed in October)	Medicare Care Compare  https://www.medicare.gov/care-compare/  Information about home health public reporting dates  https://www.cms.gov/medicare/quality/home-health/home-health-quality-reporting-data-submission-deadlines
CMS HHQRP non-compliance letters   November 2025 (usually distributed in October)	Providers will receive a letter if they are found not in compliance with quality reporting requirements – most likely there will be late distribution due to the 43-day federal government shutdown. – Providers may submit a request for reconsideration to CMS if they do not agree with the CMS outcome  – Non-compliance notifications will be distributed by the Medicare Administrative Contractors (MACs) and will be placed into provider CASPER folders in iQIES
CMS Home Health Payment Update Rule (Final) Annual CY issuance May include proposed regulatory information not included in the FY hospice payment update proposed rule  November 2025	Will first appear on the Federal Register Public Inspection Desk https://www.federalregister.gov/pu blic-inspection/current  Will move over to the Federal Register within 7 days of initial posting https://www.federalregister.gov/do cuments/current
Medicare Care Compare Refresh  Hospice quality scores are publicly reported on the Care Compare website and updated on a quarterly basis.  CAHPS star ratings are NOT updated in this quarterly refresh  November 2025	Medicare Care Compare https://www.medicare.gov/care- compare/ Information about hospice public reporting https://www.cms.gov/medicare/qu ality/hospice/public-reporting- background-and-announcements

Top Items 

Federal Government Reopens 

On November 12, the U.S. House passed the Senate Amendment to H.R. 5371, ending the 43-day government shutdown. The continuing resolution (CR) provides funding for most agencies through January 30, 2026, at current levels, and grants full-year 2026 funding to select departments, including Agriculture, FDA, Legislative Branch, military construction, and Veterans Affairs. It also contains measures relevant to the home care community.  

Telehealth waivers extended, hospice surveys refunded and return to normal federal activity information highlighted.  Read the CHAP notice for details.  

Update on Processing of Medicare Claims Impacted During the Government Shutdown 

On November 6, 2025, CMS instructed the MACs (see Update on Processing of Telehealth and Acute Hospital Care at Home Claims) to return a subset of telehealth claims submitted on or before November 10, 2025, that, at that time, were no longer payable because the statutory provisions temporarily suspending various Medicare telehealth requirements expired on October 1, 2025, or were claims CMS could not identify as payable under current law. For professional claims, those claims were returned with the following messages: CARC 16 and RARC M77. These claims are now payable, provided they meet all applicable Medicare requirements. Practitioners may resubmit those returned claims to CMS, as well as submit any other telehealth claims held in anticipation of possible Congressional action. Practitioners are also encouraged to identify which beneficiaries were charged for telehealth services with dates of service on or after October 1, 2025, that are retroactively payable and instead submit applicable claims to Medicare, refunding any overpayment to beneficiaries. Our instruction to practitioners to append the GY modifier on certain telehealth claims is rescinded and providers may resubmit previously denied claims. 

Facilities, practitioners, and suppliers should be observing a return to normal processing operations over the coming days across the MACs and do not need to contact the MACs unless you observe specific discrepancies. 

Hospice/Palliative Care Provider Updates 

Hospice Preview Reports for the February 2026 Refresh – NOW AVAILABLE IN QIES 

Because of the lapse in federal appropriations, scheduled data refreshes and other routine updates were temporarily paused. With the resumption of government operations on November 13, these updates are now being released. 

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 February 2026 refresh. 

Hospice Care Index (HCI) Measure Update CMS identified and corrected an issue affecting how the Late Live Discharge and Early Live Discharge indicators were calculated within the Hospice Care Index (HCI) measure. The correction was applied to the programming logic used in calculating these indicators to ensure that each hospice’s score reflects only the care it provided to its own patients. This correction affects a small percentage of hospice providers. 

Archived data will be updated with the corrected methodology in a future release. 

In the Provider Preview Reports, assessment-based measure scores are based on HIS data submitted by hospices from Quarter 2, 2024 through Quarter 1, 2025. CAHPS measure scores are based on CAHPS data submitted from Quarter 2, 2023 through Quarter 1, 2025. CAHPS Star Ratings are calculated based on data from Quarter 2, 2023 through Quarter 1, 2025. 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 November 18, 2025 to December 18, 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 (Assessment and Claims-based measures)  here and about the CAHPS Preview Report here. Hospice QRP Key Dates for Providers can be found here. 

Home Health Provider Updates 

Public Reporting October 2025 Refresh of HH QRP Data – Now Available 

Because of the lapse in federal appropriations, scheduled data refreshes and other routine updates were temporarily paused. With the resumption of government operations on November 13, these updates are being released.   

Effective November 20, 2025, the October 2025 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 1, 2024 through Quarter 4, 2024. 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 2, 2024 through Quarter 1, 2025. 

Due to technical issues that affected two quality measures, CMS has decided to suppress the measure results for the Transfer of Health Information to the Provider and Discharge Function Score measures for the October 2025 release. Reporting on the two measures will resume with the next refresh in January 2026. 

Please visit the compare tool on Medicare.gov and PDC to view the updated quality data.  

Preview Reports and Star Rating Preview Reports for the January 2026 Refresh of HH QRP Data – NOW AVAILABLE IN iQIES 

Because of the lapse in federal appropriations, scheduled data refreshes and other routine updates were temporarily paused. With the resumption of government operations on November 13, these updates are now being released. 

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 January 2026 refresh. 

Data contained within the Provider Preview Reports are based on quality assessment data submitted by HHAs 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 Preview Reports for the January 2026 release include one new OASIS-based measure, COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date, based on quality assessment data from Quarter 1, 2025. 

Providers have until December 18, 2025, 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. 

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

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

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

An HHA receives a CY 2025 APR if the HHA was Medicare-certified prior to January 1, 2023, had a prior year payment amount, and had sufficient data for at least five (5) quality measures to calculate a Total Performance Score (TPS) and Adjusted Payment Percentage (APP) (see Exhibit 1).   

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

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. 

Were there any corrections applied to the CY 2025 APRs resulting from granted recalculation, reconsideration, or administrator review requests? 

CMS granted a recalculation request pertaining to one (1) HHA that was incorrectly categorized as inactive and therefore did not receive a Preview CY 2025 APR. As a result, CMS added this HHA to the competing HHAs for subsequent Preliminary and Final CY 2025 APR production. This added HHA is part of the larger-volume cohort and received a Preliminary CY 2025 APR and a Final CY 2025 APR. To maintain budget neutrality across all competing HHAs within each cohort, any revisions, such as adding a competing HHA, require a rerunning of APR production. In this case, the addition of one (1) HHA to the larger-volume cohort resulted in a 0.001 higher APP for some HHAs in the larger-volume cohort. For the remaining HHAs in the larger-volume cohort, this addition did not have an impact on their APP. Note that the APP of smaller-volume HHAs were also not affected.  

No reconsideration requests – and as a result no requests for Administrator review – were received after the Preliminary CY 2025 APRs were published. As such, the APP presented in the Final CY 2025 APR is the same as the APP reported in the Preliminary CY 2025 APR. 

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/. 

2. Select the My Reports option from the Reports menu. 

3. 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). 

4. 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.” 

For program questions about the expanded HHVBP Model, contact the HHVBP Model Help Desk at HHVBPquestions@cms.hhs.gov 

Medicare Could Have Saved Approximately $993 Million in 2017 and 2018 if It Had Implemented an Inpatient Rehabilitation Facility Transfer Payment Policy for Early Discharges to Home Health Agencies 

22-A-01-020.01 

We recommend that the Centers for Medicare & Medicaid Services expand the IRF transfer payment policy to apply to early discharges to home health care. If this expanded policy had been in place, Medicare could have saved $993,134,059 in 2017 and 2018. 

$993.1M 

Potential Savings 

Status 

Open Unimplemented 

Issued to CMS 

12/07/2021 

Audit Report 

A-01-20-00501 

OIG: Incorrectly Billed Visit Units That Trigger Outlier Payments on Home Health Claims 

The OIG added “Incorrectly Billed Visit Units That Trigger Outlier Payments on Home Health Claims” audit item to their work plan in November.  Nationwide home health claims data for the most recent 30-month period shows that the average duration of a home health visit is 45 minutes. The audit will cover Medicare outlier payments for home health visits for single disciplines that were billed in excess of 4 hours. Our objective is to determine whether selected home health claims with outlier payments complied with certain Medicare billing requirements.  The report is expect in 2027. 

Home Health and Hospice Provider Updates 

Medicare Could Save Millions if It Implements an Expanded Hospital Transfer Payment Policy for Discharges to Post-acute Care 

24-A-01-002.01 

We recommend that CMS conduct an analysis of its hospital transfer payment policy for discharges to PAC and expand the policy as necessary. 

$694.0M 

Potential Savings 

Status 

Open Unimplemented 

Issued to CMS 

10/06/2023 

Audit Report 

A-01-21-00504 

Parenteral Nutrition: Prevent Claim Denials  

In 2023, the improper payment rate for parenteral nutrition was 37.1%, with a projected improper payment amount of $86.4 million (see 2023 Medicare Fee-for-Service Supplemental Improper Payment Data (PDF)). Learn how to bill correctly for these services. Review the Parenteral Nutrition provider compliance tip for more information, including: 

• Billing codes 

• Denial reasons and how to prevent them 

• Refill and documentation requirements 

DME Provider Updates 

Medicare Improperly Paid Suppliers for Intermittent Urinary Catheters  

In a report, the Office of the Inspector General found that Medicare improperly paid for catheters and kits. To avoid improper payments, review the Urological Supplies provider compliance tip for more information, including: 

• Billing codes 

• Denial reasons and how to prevent them 

• Refill and documentation requirements 

DMEPOS Fee Schedule: October 2025 Quarterly Update — Revised  

CMS removed a reference (PDF) to HCPCS Level II code E0716. 

All Providers Updates  

New Waived Tests 

Learn about updates (PDF) effective January 1, 2026: 

• Clinical Laboratory Improvement Amendments requirements 

• 2 new FDA-approved waived tests: codes, effective dates, and descriptions 

Medicare Part B 

The annual deductible for all Medicare Part B beneficiaries will be $283 in 2026, an increase of $26 from the annual deductible of $257 in 2025.   

Read the full fact sheet for more information. 

All 50 States Seek to Transform Rural Health with CMS  

CMS announced that all 50 states submitted applications for the $50 billion Rural Health Transformation Program—a landmark initiative created under the Working Families Tax Cuts legislation to strengthen health care across rural America. 

Read the full press release. 

HHS Backs AI Innovation for America’s Caregivers  

 The U.S. Department of Health and Human Services (HHS) today announced a new $2 million Caregiver Artificial Intelligence Prize Competition to support the 1 in 4 Americans serving as caregivers for older adults and people with disabilities. 

 This initiative through HHS’ Administration for Community Living (ACL) recognizes the millions of caregivers who support aging relatives and loved ones with disabilities. Their compassion and commitment form the backbone of America’s long-term care system, helping older adults and people with disabilities live with dignity and independence at home and in their communities.  

To strengthen support for family caregivers and sustain the network that helps prevent the health care system from shouldering the full burden of care, HHS is investing in innovative AI solutions. The AI Prize Competition will fund and recognize innovators developing tools that:  

• Support caregivers—including family, friends, and the direct care workforce—in providing safe, person-centered care at home.  

• Support employers by improving efficiency, scheduling, and training in the caregiving workforce.  

These tools aim to educate, assist, and reduce administrative strain so caregivers can focus on their own well-being and the people they care for.  

For updates on the competition, visit ACL’s Caregiver AI Prize Competition page.   

Updated ICD Code Lists Now Available 

Updated ICD-10 and ICD-9 valid and excluded liability and no-fault code lists for 2025 are now available on the ICD Code Lists page on CMS.gov.  

Educational Opportunities 

Save the Date! 

Mark your calendar! We are excited to announce that the 2026 CMS Quality Conference will return on March 16-18, 2026, both online and in person at the Hilton Baltimore Inner Harbor.  The premier event for healthcare quality nationwide will bring together a community of healthcare leaders, clinicians, researchers, and patient advocates dedicated to improving care, so be sure to save the date. 

More details, including registration and hotel information, will be shared in the coming months. In the meantime, let us know what you’re looking forward to by using #QualCon26 on social media or revisit the powerful presentations from the 2025 Quality Conference 

Prepping for the Future: Digital Solutions for Aging Populations 

AHRQ will host a webinar on December 17th, 2025, from 1:30 – 3:00 p.m. ET that covers how digital technologies such as remote monitoring, telehealth, and personalized health apps are transforming care for older adults by enabling timely interventions, improving access, and supporting independence. Our expert panel will explore how these tools can improve health outcomes, overcome adoption barriers, and ensure older adults benefit from accessible, user-friendly, and effective digital solutions. 

This webinar was previously scheduled for October. If you registered for that date, please re-register. 

 Register for the December 17th webinar on digital solutions for aging populations.