Compliance Monitor (12/8/25)

Your source for federal updates 

November/December 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
HH QRP Reconsideration Results	Reconsideration results delivered in November/December

Top Items 

Posted: Calendar Year 2026 Home Health Prospective Payment System Rate Update, etc. 

The final Calendar Year 2026 Home Health Prospective Payment System (HH PPS) Rate Update; Requirements for the HH Quality Reporting Program and the HH Value-Based Purchasing Expanded Model; Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program Updates; DMEPOS Accreditation Requirements; Provider Enrollment; and Other Medicare and Medicaid Policies was posted on the Federal Register Public Inspection desk on 11/28/2025.  

These regulations are effective on January 1, 2026 

Access CHAPs summary of the home health provider information in the final rule 

Access CHAPs summary of the DME provider information in the final rule 

DMEPOS Suppliers: Submit Comments by December 22  

CMS requests your comments on the Medicare Enrollment Application for DMEPOS Suppliers, Form CMS-855S. Visit the PRA Listing webpage to get the supporting statement and related forms. The comment period closes on December 22, 2025. 

HHS Unveils AI Strategy to Transform Agency Operations 

HHS released its AI Strategy, as the next phase of the Department’s transformative initiative to make artificial intelligence (AI) available to the federal workforce, integrating it across internal operations, research, and public health. It fulfills HHS’ commitment to utilize leading technologies to enhance efficiency, foster American innovation, improve patient outcomes, and Make America Healthy Again. 

Hospice/Palliative Care Provider Updates 

Outpatient Services for Hospice Patients: New Edit 

Learn about updates to hospice outpatient services (PDF) effective April 1, 2026:  

• New systems’ edits will compare primary diagnosis codes on hospital and hospice claims for Medicare hospice patients to prevent duplicate payments 

• How to properly use condition code 07  

Hospice Claims Billed by Terminated Hospices  

CMS updated the Medicare Claims Processing Manual, Chapter 11 (PDF), adding section 110 with payment procedures for terminated hospices. See the instruction to your Medicare Administrative Contractor (PDF) for more information.  

Home Health Provider Updates 

Therapy Code List: 2026 Annual Update 

Learn about updates (PDF), effective January 1, 2026, for remote therapeutic monitoring services designated as sometimes therapy:  

• New codes 

• Revised code descriptors 

Notice of Non-Compliance Related to Annual Payment Update 

Quality Reporting Program: Non-Compliance Letters for CY 2026 APU for Home Health Agencies 

The Centers for Medicare & Medicaid Services (CMS) is providing notifications to home health agencies that were determined to be out of compliance with the Home Health Quality Reporting Program (HHQRP) requirements for calendar year (CY) 2026 Annual Payment Update (APU). Non-compliance notifications will be placed into Home Health Agencies (HHA) My Reports folders in iQIES on November 26, 2025. Additionally, the Medicare Administrative Contractors (MACs) will distribute a letter by email or regular mail to non-compliant HHA’s in their service area. HHAs that receive a letter of non-compliance may submit a request for reconsideration to CMS via email no later than 11:59 pm, January 6, 2026. If you receive a notice of non-compliance and would like to request a reconsideration, see the instructions in your notification and on the Home Health Quality Reporting Reconsideration and Exception & Extension webpage. 

Please note: Any reconsideration request emails greater than 20 MB in size or containing protected health information (PHI) will not be processed. All PHI must be removed in order for a reconsideration to be reviewed. 

Expanded HHVBP Model: December 2025 Newsletter 

Interim Performance Reports (IPRs) – Preliminary October 2025 IPRs Available in iQIES 

The Preliminary October 2025 IPRs for the expanded HHVBP Model were published in the Internet Quality Improvement and Evaluation System (iQIES) on December 1^st, 2025. As of October 2025, the CY 2025 measure set is in effect. Exhibit 1 lists the three (3) OASIS-based, two (2) claims-based, and five (5) HHCAHPS Survey-based measures included in the CY 2025 applicable measure set. 

Exhibit 1: CY 2025 applicable measure set 

The October 2025 IPRs also include a preview of the benchmarks, achievement thresholds, and improvement thresholds for the forthcoming CY 2026 applicable measure set. 

Who is eligible to receive an October 2025 IPR?  

An HHA receives an October 2025 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 performance period shown in Exhibit 2. 

Exhibit 2: October 2025 IPR measure performance period by measure category 

IMPORTANT NOTE: CMS recalculated Improvement Thresholds based on CY 2024 for the OASIS-based Discharge Function (DC Function) measure reported on the “CY 2025 Baseline” tab in the July 2025 IPRs. HHAs that received a July 2025 IPR, please go through the following steps to identify if you were impacted by this correction: 

1. Open your HHA’s July 2025 IPR and navigate to the “CY 2025 Baseline” tab.  
   • If you did not receive a July 2025 IPR and/or October 2025 IPR, no further action is required on your part. 
2. Locate the column labeled “Baseline Year Data Period [b].  
   • If you see “12-31-2024” in this column for the OASIS-based DC Function measure, the corresponding Improvement Threshold (listed in the adjacent column labeled “Your HHA’s Improvement Threshold”) was recalculated. Your HHA’s October 2025 IPR shows the correct CY 2024 Improvement Threshold for this measure. 
   • If you see “12-31-2023” in this column for the OASIS-based DC Function measure, no corrections were made to your Improvement Threshold as the CY 2023 measure data were not impacted. 

For any questions related to this correction of the CY 2024 Improvement Thresholds for the OASIS-based DC Function measure, please contact the HHVBP Model Help Desk at HHVBPquestions@cms.hhs.gov. 

 Please note that IPRs are not available to the public. IPRs are only available to HHAs in the “HHA Provider Preview Reports” folder in iQIES. Instructions on how to access the IPRs are also available on the Expanded HHVBP Model webpage, under “Model Reports.” 

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

The Final CY 2025 APRs for the expanded HHVBP Model were published in iQIES on November 13^th, 2025. The CY 2025 APRs provide the HHA’s Adjusted Payment Percentage (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). 

Who is eligible to receive a CY 2025 APR?  

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 quality measures to calculate a TPS and APP.   

Exhibit 3: CY 2025 APR measure performance period by measure category 

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

Yes, 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. 

Please note that APRs are not available to the public. APRs are only available to HHAs in the “HHA Provider Preview Reports” folder in iQIES. Instructions on how to access the APRs are also available on the Expanded HHVBP Model webpage, under “Model Reports.” 

Will the second performance year’s results be available in the Provider Data Catalog? 

Yes, CMS will post results from the second performance year of the expanded HHVBP Model (CY 2024) in the Provider Data Catalog (PDC) in January 2026. Note that the results from the first performance year (CY 2023) will also still be available but moved to the home health services data archive once the second year’s performance results are publicly available. Please review the Public Reporting Tip Sheet: Home Health Value-Based Purchasing for additional details on HHVBP public reporting. 

Reminder: CMS Wants to Hear from You – Call for Information  

Have your HHVBP Model performance results been used with or by referral sources, state Medicaid agencies, or managed care entities? If the answer is “yes”, CMS would like to hear from you! Send your experiences to HHVBPquestions@cms.hhs.gov. The June 2025 HHVBP Newsletter (page 5) includes additional details on what CMS is interested in learning. 

This Call for Information is optional. CMS encourages interested HHAs to submit their stories (narratives up to three paragraphs) summarizing their experiences along with any applicable CCN(s) and contact information to the HHVBP Help Desk at HHVBPquestions@cms.hhs.gov. Thank you in advance for your partnership and support. 

Home Health & Hospice Provider Updates 

Home Health & Hospice Resources: Talk to Your Patients About Medicare-Covered Services  

Medicare covers a wide range of home health and hospice services. During Home Care & Hospice Month, get familiar with these Medicare Learning Network® resources:  

• Medicare Payment Systems: 
  • Home Health Prospective Payment System & Coverage 
  • Hospice Payment System & Coverage 
• Creating an Effective Hospice Plan of Care fact sheet 
• Enhancing Registered Nurse Supervision of Hospice Aide Services (PDF) fact sheet 
• Safeguards for Medicare Patients in Hospice Care (PDF) fact sheet  

Information for Patients:  

• Care Compare: Search for home health services or hospice care 
• Home Health: 
  • Home health services webpage 
  • Medicare & Home Health Care booklet 
• Hospice: 
  • Hospice care webpage 
  • Medicare Hospice Benefits booklet 
  • Medicare & Hospice Benefits: Getting Started brochure 

DME Provider Updates 

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 

OIG Releases New Video on Combating DME Fraud 

OIG releases a new video on combating durable medical equipment fraud. Durable Medical Equipment (DME), like wheelchairs, oxygen tanks, and glucose monitors, is essential for millions of Americans. But this vital support system is also a frequent target for fraud, costing taxpayers billions and putting patients at risk. OIG is working to stop DME fraud through investigations, audits, evaluations, and data analytics. The new video explains how these schemes work, how they impact real people, and what you can do to protect yourself and your loved ones.  

Watch the video to learn more 

Durable Medical Equipment, Prosthetics, Orthotics, and Supplies Competitive Bidding Program – Updates and Important Information 

CMS is making some important changes in the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program (CBP) so that we can protect the Medicare Trust Funds and lower copays for beneficiaries. Access this document to learn about the 20206 CBP timeline and what’s new. 

All Providers Updates  

HHS’ Cleanup of Federal Nursing Home Minimum Staffing Standards Rule Expands Access to Rural and Tribal Health Care 

Note to hospice providers: this may impact care of your patients in nursing facilities. 

HHS repealed provisions of the Minimum Staffing Standards for Long-Term Care (LTC) Facilities and Medicaid Institutional Payment Transparency Reporting Final Rule, the CMS.  The 2024 rule had established a federal requirement that nursing homes participating in Medicare and Medicaid provide residents with a minimum total of 3.48 hours of nursing care per day, including at least 0.55 hours from a registered nurse per resident per day, and 2.45 hours from a nurse aide per resident per day, along with requirements that each facility have a registered nurse onsite 24/7. These measures disproportionately burdened rural and underserved communities already grappling with critical health care workforce shortages. 

ACCESS Model Expands Access to Technology-Supported Care in Original Medicare  

What’s New: The Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model tests an outcome-aligned payment approach designed to give people with Original Medicare new options to improve their health and prevent and manage chronic disease with technology-supported care. The voluntary model focuses on common conditions, such as high blood pressure, diabetes, chronic musculoskeletal pain, depression, and other conditions affecting millions of Americans. 

Why It Matters:  Today, people with Original Medicare have limited access to modern, technology-supported care for managing their chronic conditions. 

What to Expect:  CMS will begin accepting applications for the 10-year voluntary model on January 12, 2026, with an initial deadline of April 1, 2026. ACCESS will begin July 1, 2026. The Request for Applications will be available soon; the ACCESS Model Interest Form can be completed to be notified when the application becomes available. 

Visit the ACCESS Model webpage for more information. 

Medicare Participating Physician or Supplier Agreement Form Expired on November 30, 2025  

The Medicare Participating Physician or Supplier Agreement (PDF) Form CMS-460 expires on November 30, 2025. It’s currently under review by the Office of Management and Budget (OMB).  

Medicare Administrative Contractors will continue to accept the current version of the form dated after November 30, 2025. Communication will occur when OMB approves the updated form. 

CMS Posts Memo, Questions + Answers for State Recovery after the Federal Government Shutdown 

CMS posted a SOG Memo titled, “Questions + Answers for State Recovery after the Federal Government Shutdown”, QSO-26-02-ALL on 11/24/2025.  The document contains responses to questions CMS received from States and providers with regard to the manner in which survey, enforcement & certification activities should accommodate the effects of the federal government shutdown that occurred from October 1, 2025, through November 12, 2025.  

Wasteful and Inappropriate Service Reduction (WISeR) Model Office Hour for Providers 

The CMS Innovation Center will host an office hour for providers to discuss the WISeR Model’s impact on providers, address frequently asked questions and respond to live inquiries from the audience. We encourage you to submit questions in advance using the registration form linked below. 

Please share this event with colleagues who may be interested in this topic. Following the event, presentation materials will be available on the WISeR Model webpage.  You may contact the WISeR Model Team at WISeR@cms.hhs.gov. 

WISeR Model Office Hour for Providers Date and Time: 

Thursday, December 4, 2025, 1:00 – 2:00 PM EST  

Registration link: 

https://deloitte.zoom.us/webinar/register/WN_7M7sLRsJSkK1mF90_JWl8Q

Crush Fraud  

Help CMS fight fraud, waste, and abuse. Learn about our actions to crush fraud conducted by DMEPOS suppliers and find updated information at our Crushing Fraud, Waste & Abuse webpage, including: 

• Urgent fraud scheme alerts 

• Recent successes 

• Fast facts 

• How to report 

Educational Opportunities 

HCPCS Public Meeting — December 17–18  

Wednesday, December 17 and Thursday, December 18, from 9 am – 5 pm ET 

Attend the virtual public meeting for the second biannual 2025 HCPCS Level II coding cycle. Visit the HCPCS Level II Public Meetings webpage for more information, including: 

• Meeting materials 

• Guidelines 

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. 

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