Compliance Monitor (3/27/26)
The Compliance Monitor
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 |
| April Compliance Item | |
| OASIS-E2 CMS is implementing OASIS-E2, an “off-cycle” update to the home health assessment instrument aimed at refining data collection and improving alignment across post-acute settings. All assessments completed on or after this date must use the E2 version. Effective April 1, 2026 | The final OASIS-E2 Instruments (All Items and Time Point versions) and OASIS-E2 Change Table, effective April 1, 2026, are available Outcome and Assessment Information Set OASIS-E2 Manual OASIS Data Sets |
March is National Social Workers Month – CHAP thanks you for all you do!
Top Items
Update for the March 31 Webinar: Health Care Claims Attachments Transactions & Electronic Signatures Final Rule (CMS-0053-F)
Due to an overwhelming response from the healthcare community, the highly anticipated Health Care Claims Attachments Transactions & Electronic Signatures Final Rule (CMS-0053-F) webinar taking place on Tuesday, March 31, 2026, will now be held as a Town Hall. Registration is no longer required, and the access link has changed from what was previously shared. This new format better accommodates maximum participation and reflects the extraordinary level of interest on this landmark rule.
The town hall is open to everyone from 1:00pm - 2:30pm ET, and can be accessed through the following link: Join the Town Hall Here
To make the most of the town hall, we encourage attendees to submit questions in advance to: administrativesimplification@cms.hhs.gov since we are unable to conduct a live Q&A session. BOOKMARK THIS LINK AND PREPARE TO JOIN US AT 1:00PM ET ON MARCH 31ST! Join the Town Hall Here.
View the final rule in the Federal Register: https://www.federalregister.gov/d/2026-05676
March 2026 Report to the Congress: Medicare Payment Policy
- Recommendation for home health – MedPAC review indicates that FFS Medicare payments for home health care are substantially in excess of costs. Home health care can be a high-value benefit when it is appropriately and efficiently delivered, but payments need to be reduced to align aggregate payments more closely with aggregate costs. The Commission recommends that, for calendar year 2027, the Congress reduce the 2026 Medicare base payment rate for HHAs by 7 percent.
- Recommendation for hospice – Under current law, the FFS Medicare base payment rate for hospice services is projected to increase by 2.3 percent in 2027. Based on the positive indicators of payment adequacy and the strong FFS Medicare margins, current payment rates appear sufficient to support the provision of high-quality care without an increase to the payment rates in 2027. The Commission recommends that the Congress eliminate the update to the hospice base payment rates for fiscal year 2027.
CMS Rulemaking
Final Rule – Administrative Simplification
CMS) has finalized the Administrative Simplification; Adoption of Standards for Health Care Claims Attachments Transactions and Electronic Signatures Final Rule (CMS-0053-F). The final rule slashes wasteful spending and antiquated paperwork by swapping out faxing and mailing for streamlined electronic transactions. This action lets providers spend less time on administrative hassle and more time caring for patients.
The Administrative Simplification; Adoption of Standards for Health Care Claims Attachments Transactions and Electronic Signatures Final Rule is projected to save the healthcare industry roughly $781 million annually by establishing national standards for the electronic exchange of clinical documentation used to support health care claims. The rule also adopts standards for electronic signatures to ensure secure, authenticated transmission of this information.
The rule is effective on May 19, 2026 [60 days after publication in the Federal Register]. Covered entities must comply by May 19, 2028 [24 months of the effective date].
To view the final rule fact sheet, visit: https://www.cms.gov/newsroom/fact-sheets/administrative-simplification-adoption-standards-health-care-claims-attachments-transactions.
For more information, visit: https://www.cms.gov/priorities/key-initiatives/burden-reduction/administrative-simplification/hipaa/events-latest-news.
To view the final rule, visit https://www.federalregister.gov/.
CRUSH Initiative – Request for Stakeholder Input
CMS is seeking stakeholder input, based on their experience and knowledge, on additional ways the agency can tackle fraud prevention to inform the development of a possible future rule under CMS’s 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 30, 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).
Request for Comment: Extension of a currently approved collection; Title of Information Collection: Medicaid Program Face-to-Face Requirements for Home Health Services and Supporting Regulations
CMS is announcing an opportunity for the public to comment on CMS’ intention to collect information from the public. Interested persons are invited to send comments regarding the burden estimate or any other aspect of this collection of information, including the necessity and utility of the proposed information collection for the proper performance of the agency’s functions, the accuracy of the estimated burden, ways to enhance the quality, utility, and clarity of the information to be collected, and the use of automated collection techniques or other forms of information technology to minimize the information collection burden.
Physicians (or for medical equipment, authorized non-physician practitioners (NPPs) including nurse practitioners, clinical nurse specialists, and physician assistants) must document that there was a face-to-face encounter with the Medicaid beneficiary prior to the physician making a certification that home health services are required. The burden associated with this requirement is the time and effort to complete this documentation. The burden also includes writing, typing, or dictating the face-to-face documentation and signing/dating the documentation.
Hospice/Palliative Care Provider Updates
Hospice Care Accountability, Reform, and Enforcement (Hospice CARE) Act Goes Back to Congress
Rep. Linda T. Sánchez (D-Calif.) and Sen. Mark Warner (D-Va.) have re-introduced the Hospice Care Accountability, Reform, and Enforcement (Hospice CARE) Act, designed to modernize the Medicare Hospice Benefit, fight fraud and expand access to care.
The bill combines program integrity measures with payment reforms that lawmakers say would strengthen the benefit. It would add safeguards to keep fraudulent providers from enrolling in Medicare and increase federal oversight of hospices. The legislation would also adjust payment structures to reward high-quality care.
CMS adopted the 2012 LSC on July 5, 2016, therefore all CMS-certified facilities classified as new or existing health care occupancies located in a high-rise building must have an approved, supervised automatic sprinkler system throughout the entire building by July 5, 2028.
Facilities subject to this LSC provision that have not begun to install a sprinkler system or expanded existing sprinkler coverage, as necessary, are highly encouraged to begin the process.
Acute Care Hospital Outpatient Services for Hospice Enrollees: Reduce Improper Payments
In a report, the Office of Inspector General found that Medicare improperly paid acute-care hospitals for outpatient services provided to hospice enrollees. To avoid improper payments, request and analyze hospice election statement addendums for these enrollees.
Review the Acute Care Hospital Inpatient Prospective Payment System educational tool for more information:
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.
Home Health Provider Updates
Medicare Coverage of Diabetes Supplies – Revised
CMS clarified (PDF) that they cover diabetes supplies during an inpatient stay under Medicare Part A.
DMEPOS Updates
Billing Medicare Part B for Insulin with New Limits on Patient Monthly Coinsurance – Revised
CMS added more information (PDF) on what type of insulin and insulin pumps we cover under Medicare Part B.
ICD-10 & Other Coding Revisions to National Coverage Determinations: April 2026 Update – Revised
CMS added a link (PDF) to the Medicare Claims Processing Manual update.
All Providers Updates
New ASPIRE Model to Deliver Support to Children and Youth with Complex Medical Needs
CMS is launching the Accelerating State Pediatric Innovation Readiness and Effectiveness Model (ASPIRE) Model to help children up to age 21 with complex medical and behavioral needs live healthier lives through whole-person care delivery in Medicaid and CHIP, including wrap-around services to address physical and behavioral health needs.
ASPIRE builds upon lessons learned from the Integrated Care for Kids (InCK) Model, including the benefits of integrated care management for families, and the importance of a program design that reflects the unique state-based systems serving children. ASPIRE participants will assume accountability for the quality and cost of care for ASPIRE’s target population while including care delivery requirements focused on children and youth with complex medical and/or behavioral needs.
Find out more
2026 CMS Burden Reduction Conference: Recordings and Key Takeaways
On February 25, 2026, the Centers for Medicare & Medicaid Services (CMS) had the pleasure of hosting the 2026 CMS Burden Reduction Conference. Thank you to everyone who joined us, both in person and virtually, and contributed to such a thoughtful and energizing discussion.
Conference videos are now available here.
This year’s conference featured a keynote address from CMS Administrator Dr. Mehmet Oz, opening remarks from CMS Chief Operating Officer and Deputy Administrator Kim Brandt, closing remarks from CMS Center of Medicare Director, Deputy Administrator, and HHS Chief Counselor Chris Klomp, and panel discussions focused on:
- Increasing transparency in healthcare
- Transforming chronic care
- Using technology and AI tools to empower clinicians and patients
What CMS Heard
Across conversations, several clear and actionable themes stood out:
- A call for faster, more measurable action
- Stakeholders are looking to CMS to simplify requirements, better align programs, and deliver changes that are clear and trackable.
- Prior authorization is a top near-term opportunity
- Participants emphasized more standardized, transparent, and automated processes, including reduced documentation and real-time decisions.
- Stronger Medicare Advantage oversight can reduce downstream burden
- Clearer expectations and more consistent enforcement across MA plans were seen as key to reducing friction for providers and improving patient experience.
- Administrative burden impacts patient access
- Burden is not just operational, it contributes to delays in care, clinician burnout, and reduced capacity.
- Technology should reduce work, not add to it
- Stakeholders support AI and digital tools that eliminate manual processes and integrate into existing workflows.
Advance Beneficiary Notice of Noncoverage: Updated Form
The Office of Management and Budget approved the updated Advance Beneficiary Notice of Noncoverage (Form CMS-R-131). It’s available in English and Spanish. CMS improved the readability and design.
You may use the updated form now, but you must use it starting May 12, 2026, when the previous version expires.
Medicare Shared Savings Program: Application Deadlines for January 1, 2027, Start Date
Accountable Care Organizations (ACOs): See the Medicare Shared Savings Program Application Types & Timeline webpage to learn about key dates for a January 1, 2027, start date. CMS will accept applications starting June 9 through the ACO Management System. Apply no later than June 23 at noon ET.
Medicare Payment Systems — Revised
Learn about updates for 2026. See the What’s Changed sections under each payment system for the latest information.
FDA Launches New Adverse Event Look-Up Tool
The FDA launched a new unified platform for analyzing adverse event reports. This platform — called the FDA Adverse Event Monitoring System (AEMS). With the new system, adverse event reports submitted to the FDA for drugs, biologics, vaccines, cosmetics, and animal food can be displayed in a single streamlined dashboard. In the months ahead, all remaining product centers will begin processing adverse event reports in AEMS. The agency will also migrate historical adverse event data to AEMS, decommission certain legacy systems, and roll out enhanced application program interfaces (APIs) and data analytics tools. By the end of May 2026, AEMS will contain real-time adverse event reports for all FDA-regulated products, consistent with meeting agency obligations not to release individually identifiable patient or consumer information.
The U.S. Department of Labor’s Occupational Safety and Health Administration announced the launch of its OSHA Cares initiative, an agency-wide effort focused on helping businesses meet federal workplace safety requirements, while also building strong, successful safety and health programs that benefit employers and workers.
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.”
Emergency Preparedness Resources
Emergency Preparedness: Find Out How to Prevent Deficiencies
CMS and the Administration for Strategic Preparedness and Response’s Technical Resources, Assistance Center, and Information Exchange (ASPR TRACIE) analyzed frequently cited emergency preparedness deficiencies. Visit the updated CMS Health Care Provider Guidance webpage for more information, including top trending citations (PDF).
More Information:
- CMS:
- ASPR/TRACIE:
- Continuity of Operations / Business Continuity Planning Topic Collection
- Emergency Operations Plans / Emergency Management Program Topic Collection
- Hazard Vulnerability / Risk Assessment Topic Collection
- Training & Workforce Development Topic Collection
- Challenges & Considerations for Healthcare Facilities and Residents Affected by Planned Power Outages Sidebar
- Populations with Access & Functional Needs Topic Collection