Compliance Monitor (3/10/26)

Your source for federal updates

March 2026 Compliance Activity

Compliance Item & Date	Additional info & Links
CMS Hospice Payment Update Rule (NPRM) – Annual FY issuance – Includes proposed annual payment update and quality program information Other proposed regulations or changes to standing regulations may be included with the opportunity for comments (as applicable)	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
MedPAC report to Congress – Annual issuance – Includes data analysis of Medicare hospice utilization and spending and recommendations to Congress Posted in mid-March	MedPAC report webpage https://www.medpac.gov/document-type/report/
OSHA Form 300-A form Form 300-A is the Summary of Work- Related Injuries and illnesses At the end of each calendar year, Form 300- A must be completed and certified by a company executive as correct and complete and posted in the workplace annually, where notices to workers are usually posted. The completed form must be submitted to OSHA by early March The completed form must be posted for three months, from February 1 until April 30	Establishments under Federal OSHA jurisdiction can use the ITA Coverage Application to determine if they are required to electronically report their injury and illness information to OSHA. Establishments under State Plan jurisdiction should contact their State Plan. https://www.osha.gov/news/newsreleases/tr ade/01092023 Form 300-A https://www.osha.gov/recordkeepi ng/forms
OSHA The deadline for covered employers to submit their calendar year 2025 injury and illness data (Form 300A, and in some cases Forms 300 and 301) through the OSHA Injury Tracking Application (ITA) is March 2, 2026.	This applies to establishments with 250 or more employees, or those with 20–249 employees in designated high-risk industries. https://www.osha.gov/injuryreporting

March is National Social Workers Month – CHAP thanks you for all you do!

Top Items

CMS Announces Nationwide DMEPOS Temporary Enrollment Moratorium

CMS posted an “Announcement of Nationwide Temporary Moratoria on Enrollment of Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Supplier Medical Supply Companies” on 2/25/2026. The effective date of the moratorium is 2/27/2026.

More Information:

Provider Enrollment Moratoria webpage

FAQs (PDF)

Nationwide Temporary Moratoria on Enrollment of DMEPOS Supplier Medical Supply Companies notice

Read the CHAP summary.

MAC MBI Lookup Tool: Keep Your Access During Enhanced Monitoring

CMS identified a concerning trend of malicious actors stealing MBIs and using them to commit Medicare fraud. Some are misusing Medicare Administrative Contractor (MAC) MBI lookup tools. We’re implementing enhanced monitoring controls to prevent this abuse.

Only use the MAC MBI lookup tool for people you intend to provide a service or product to that you’ll bill to Medicare. Our enhanced monitoring compares the MBIs you look up against actual claims submitted with NPIs. If we notice an unusually high rate of MBI lookups without associated claims, your access to the lookup tool may be removed.

Take Action to Maintain Access: Complete MAC Portal Updates by May 7

Make sure your MAC portal users are associated with NPIs in your organization on whose behalf they may perform MBI lookups. This helps us verify legitimate use and protects your access to the lookup tool. 

CMS Rulemaking

CRUSH Initiative – Request for Stakeholder Input

CMS is looking to stakeholders to provide input, based on their experience and knowledge, on additional ways the agency can tackle fraud prevention to help inform the development of a possible future rule under CMS’ Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH) initiative. The CRUSH request for information (RFI) seeks input from a broad range of stakeholders – including states, providers, suppliers, payers, technology companies, patient advocates, beneficiaries, and others – on ways to strengthen CMS’ ability to prevent, detect, and respond to fraud, waste, and abuse, and program inefficiencies in Medicare, Medicaid, the Children’s Health Insurance Program (CHIP), and the Health Insurance Marketplace. Stakeholders can provide input on both existing authorities, as well as ideas for new regulatory approaches.

Comments on the CRUSH Request for Information must be submitted by March 20, 2026, via the Federal Register at: https://www.federalregister.gov/public-inspection/2026-03968/request-for-information-comprehensive-regulations-to-uncover-suspicious-healthcare (refer to CMS-6098-NC).

The FY 2027 Hospice Wage Index, Payment Rate Update, and Quality Reporting Requirements (CMS-1851-P)

The FY 2027 Hospice Wage Index, Payment Rate Update, and Quality Reporting Requirements (CMS-1851) proposed rule entered the review queue of the Office of Management and Budget on 2/26/2026. The proposed rule is usually posted in the Federal Register late March/early April. CHAP will review the rule when it is posted and develop a summary which we will post on our website.

Hospice/Palliative Care Provider Updates

Hospice Quality Measures Users Manual v1.04 (Effective October 1, 2025)

CMS has posted an update to the QM Users Manual to clarify language about measure calculations, a corresponding v1.04 Change Table, and an updated Current Measures list. 

These updated materials can be located in the Downloads section of the Current Measures | CMS webpage.

Home Health Provider Updates

NOW AVAILABLE: HHQRP QM Users Manual 3.1 and the 2026 Risk Adjustment Technical Specification Report

The Centers for Medicare & Medicaid Services (CMS) has HHQRP QM User’s Manual 3.1, HHQRP QM Manual 3.1 Change Table, and the 2026 Risk Adjustment Technical Specification Report.  These documents provide updates to QM calculations and outline new steps for determining home health quality episodes. Please find both documents in the Downloads section on the Home Health QRP Quality Measures webpage.

Expanded HHVBP Model: Final January 2026 Interim Performance Reports (IPRs) are Available in iQIES

Final January 2026 Interim Performance Reports (IPRs) are Available in iQIES

The Final 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

* Not included in the TPS calculation for HHAs in the smaller-volume cohort. For additional details on cohort assignment in the expanded Model, please review Section 2 in the Expanded HHVBP Model Guide, available on the Expanded HHVBP Model webpage, under “FAQs & Model Guide.”

Accessing IPRs

IPRs 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. IPRs are not available to the public. For assistance with downloading your HHA’s IPR, 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.

 Log into iQIES at https://iqies.cms.gov/.

Select the My Reports option from the Reports menu.

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).

Select the HHVBP report file, and the contents of the file will display.

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

DMEPOS 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 Complying with 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

All Providers Updates

Trump Administration Prioritizes Affordability by Announcing Major Crackdown on Health Care Fraud

On February 25, at the White House, Vice President J.D. Vance, HHS Secretary Robert F. Kennedy, Jr., and CMS Administrator Dr. Mehmet Oz announced new steps to crack down on fraud in Medicare and Medicaid to protect patients and taxpayers and improve affordability. The actions include deferring $259.5M of quarterly federal Medicaid funding in Minnesota to prevent payment of questionable claims while further investigation is completed; a nationwide moratorium on Medicare enrollment for certain DMEPOS suppliers; and a nationwide call to action for Americans to support fraud prevention, including stakeholder input on how CMS can continue to expand and strengthen its efforts. Together, these steps reflect a coordinated, data-driven strategy to prevent fraud before it occurs, hold bad actors accountable, and protect taxpayer dollars. 

More Information:

Full press release

Nationwide Temporary Moratoria on Enrollment of DMEPOS Supplier Medical Supply Companies notice

Request for Information: Comprehensive Regulations to Uncover Suspicious Healthcare proposed rule: Submit comments by March 20

Crushing Fraud, Waste, & Abuse webpage

Medicare Physician Fee Schedule Database: April Update

See the instructions to your Medicare Administrative Contractor (MAC) (PDF) to learn about the April quarterly updates to the Medicare Physician Fee Schedule Database, including:

New codes

Procedure status changes

Short descriptor code revisions

Payment policy indicator changes

Your MAC will give you 30-days notice before they implement these changes. After that, they’ll adjust claims that you bring to their attention.

For more information, see the Medicare Claims Processing Manual, Chapter 23 (PDF), section 30.1.

No-Pay Medicare Summary Notice Mailing Frequency Changed to Every 180 Days 

The frequency of No-Pay Medicare Summary Notices (MSNs) changed from every 120 days to every 180 days, effective January 1, 2026. Remind your patients that they can go digital to get their MSNs electronically. 

More Information:

Medicare Claims Processing Manual, Chapter 21 (PDF), sections 10 and 10.1

Instructions to your Medicare Administrative Contractor (PDF)

FDA to Address Unused Opioids in American Homes

The FDA issued a Request for Information (RFI) seeking public comment on potential new standards for in-home opioid disposal products. This effort is part of the agency’s broader work to combat the opioid crisis.

Companies selling opioid analgesics are currently required to make available prepaid mail-back envelopes to outpatient pharmacies and other dispensers. Now, the agency is considering whether to require that opioid sponsors, through dispensers, make available in-home disposal systems.

The RFI seeks input from industry, health care providers, and advocates on appropriate criteria for in-home disposal kits. This aligns with the SUPPORT for Patients and Communities Reauthorization Act of 2025, which mandates the FDA to issue guidance to facilitate in-home safe disposal, as well as President Trump’s Great American Recovery initiative.  

Responses to the RFI are due by 11:59 p.m. Eastern Time on April 6, 2026. All interested parties are invited to submit comments to the docket.

Medicare.gov Enhanced Log In

CMS released Medicare.gov Enhanced Login options. By providing people with Medicare these options, Medicare.gov is helping users better manage their health care information by delivering more login choices. People with Medicare do not need to create an account to access general Medicare information or their individualized Medicare information. If someone chooses to create an account, Medicare is providing new and free options with enhanced security to help protect their Medicare information. 

Educational Opportunities

Explore the 2026 QualCon Agenda.

Are you planning to attend the 2026 CMS Quality Conference taking place March 16–18 at the Baltimore Hilton Inner Harbor and online? Get ready to dive into sessions designed to support collaboration, innovation, and action as we come together around the theme “Make America Healthy Again: Innovating Together for Better Health.”

Across this year’s conference, QualCon26 will feature: 

CMS Administrator, Mehmet Oz, MD, MBA
CMS and HHS Leadership Panel discussions
Microsoft’s Global Chief Medical Officer and Vice President of Healthcare, David Rhew, MD, a national leader in clinical innovation and emerging technology
Exciting Breakout Sessions including:
- Leveraging AI to improve patient safety
- Eat Well, Live Well: Translating Nutrition Science into Practice
- Accelerating Prevention Through Performance Measurement: National Leaders Explore Opportunities in AI, Methods, and Data Streams
- And more!

Explore the agenda outline and plan your experience today. Let us know that you’ll be attending and what you’re looking forward to on social media with #QualCon26.

Space is limited so register ASAP to be part of these important conversations and join the dialogue on social media using #QualCon26.

REGISTER HERE

Where to Stay

Take advantage of special room block at the Hilton Baltimore Inner Harbor or the Lord Baltimore for $150 per night.

Resources

CMS Resources to Improve Quality of Care:

Check out CMS’s new Quality in Focus interactive video series.  The series of 10–15 minute videos are tailored to provider types and aim to reduce the deficiencies most commonly cited during the CMS survey process, like infection control and accident prevention.  Reducing these common deficiencies increases the quality of care for people with Medicare and Medicaid.

Learn to: