Compliance Monitor (4/30/26)
Your source for federal updates
April 2026 Compliance Activity
| Compliance Item & Date | Additional info & Links |
| 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 |
| The FY 2027 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Program Requirements Comments due on June 1, 2026 | FY 2027 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Program Requirements Read the CHAP summary of the proposed rule. |
| HHCAHPS Changes: CMS will update the HHCAHPS survey and remove three survey-based measures from the expanded HHVBP Model: Care of Patients, Communications between Providers and Patients, and Specific Care Issues. Beginning April 1, 2026 | Calendar Year (CY) 2026 Home Health Prospective Payment System Final Rule (CMS-1828-F) |
| CMS updated the Medicare DMEPOS Master List, including 83 items on the Required Face-to-Face (F2F) and Written Order Prior to Delivery (WOPD) List and 74 items on the Required Prior Authorization List. Key changes include added codes for oxygen systems (F2F/WOPD) and orthoses/pneumatic compressors (Prior Authorization) to reduce improper payments. Order Prior to Delivery List, and the Required Prior Authorization List are effective on April 13, 2026 | https://www.cms.gov/data-research/monitoring-programs/medicare-fee-service-compliance-programs/medical-review-and-education/dmepos-order-requirements#:~:text=On%2C%20January%2013%2C%202026%2C,Order%20Prior%20to%20Delivery%20List. |
| Medicare Care Compare Refresh Home health quality scores are publicly reported on the Care Compare website and updated on a quarterly basis. Before each quarterly release of data, Home health providers should review their quality measure results during a 30-day preview period using the Provider Preview Report available in iQIES. April 2026 | 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 |
Top Items
CMS and the FDA announced the Regulatory Alignment for Predictable and Immediate Device (RAPID) coverage pathway, a new pathway designed to expedite access to certain FDA-designated Class II and Class III Breakthrough Devices for people with Medicare.
The RAPID coverage pathway is for Breakthrough Devices that address unmet medical needs among Medicare beneficiaries and is available for certain Class II devices participating in the FDA Total Product Life Cycle Advisory Program (TAP) and Class III devices regardless of whether they are participating in TAP. To be eligible for the RAPID coverage pathway, devices must be the subject of an Investigational Device Exemption (IDE) study that enrolls Medicare beneficiaries and studies clinical health outcomes agreed upon by the FDA and CMS.
A proposed procedural notice outlining the RAPID coverage pathway will soon be published in the Federal Register. The public will have 60 days to provide comments on the procedural notice. CMS will respond to public comments in a subsequent final notice. The effective date of the new pathway is expected to occur upon publication of the final notice in the Federal Register. Interested parties should look to the upcoming Federal Register publication for details on the RAPID coverage pathway and how to provide comments.
CMS Announces Resources, Flexibilities to Assist with Public Health Emergency in State of Hawaii
CMS announced additional resources and flexibilities available in response to a Public Health Emergency (PHE) in the State of Hawaii due to emergency conditions resulting from severe storms, flooding, landslides, and mudslides beginning March 10, 2026, and continuing. CMS is working closely with the State of Hawaii and federal partners to put flexibility in place to ensure those affected by this natural disaster have access to needed care.
CMS’ blanket waivers and other flexibilities are available to affected providers in Hawaii who have been affected by severe storms, flooding, landslides, and mudslides – retroactively from March 10, 2026. Healthcare providers in need of additional flexibilities specific to the effects resulting from severe storms, flooding, landslides, and mudslides can submit a request to CMS here: CMS 1135 Waiver/Flexibility Request and Inquiry Form.
Visit this link to read more flexibilities: https://www.cms.gov/newsroom/news-alert/cms-announces-resources-flexibilities-assist-public-health-emergency-state-hawaii
CMS Launches First Wave of HealthTech Ecosystem Tools, Fast-Tracking a Fully Digital, Patient-Centered Health System
A major leap forward in modernizing America’s healthcare system was announced during the Centers for Medicare & Medicaid Services (CMS) HealthTech Ecosystem Live! First Wave Launch event, which brought together CMS infrastructure, a new Medicare App Library, and an initial set of patient-facing applications to move the nation beyond clipboards, fax machines, and repetitive paperwork into a seamless, digital-first era.
Interoperable digital tools were introduced intended to streamline care and improve the patient experience. Highlights included:
- Digital data access and check-in (“Kill the Clipboard”), allowing patients to securely share information with a simple scan on their phone.
- Personalized health applications, offering tailored guidance on nutrition, wellness, and chronic disease management—extending care beyond clinic walls.
For more information on CMS’ HealthTech Ecosystem, visit: https://www.cms.gov/priorities/health-technology-ecosystem/overview
HETS Action Required: Enroll Third-Party Vendors for Access by May 11, 2026
Providers using third-party vendors to check Medicare beneficiary eligibility must now enroll these vendors with CMS for HIPAA Eligibility Transaction System (HETS) access by linking each vendor to your NPI.
If you haven’t already enrolled, visit HETS EDI: How to Enroll, and follow these steps:
- Contact your vendor promptly
- Obtain their unique ID
- Use the ID to enroll and link the vendor to your NPI so they can continue submitting eligibility inquiries
Complete enrollment by May 11 to avoid service disruption.
If you opt not to enroll, you may still check eligibility through your Medicare Administrative Contractor’s secure internet portal. After enrollment, you’ll receive monthly transaction volume reports for each vendor you enrolled.
Questions?
- For report questions, contact your vendor
- If you have concerns about your NPI being misused to check eligibility, contact mcare@cms.hhs.gov
CMS Rulemaking
CMS Proposes Major Reforms to Speed Up Patient Access to Drugs, Increase Transparency, and Reduce Administrative Burden
Proposed rule would require faster prior authorization decisions, expand electronic prior authorization to drugs, and increase transparency across federal programs
CMS is proposing changes to slash long waiting periods for drugs, reducing barriers to timely access to critical treatments. The Interoperability Standards and Prior Authorization for Drugs proposed rule would advance sweeping reforms to modernize prior authorization for drugs by establishing clear decision deadlines for impacted payers – no later than 24 hours for urgent requests and 72 hours for standard requests – and increasing transparency through full disclosure of claims denials and appeals outcomes.
The rule also proposes adopting Fast Healthcare Interoperability Resources (FHIR®)-based standards to replace the outdated X12N 278 transaction standard currently used by a minority of health plans. This would enable real-time electronic workflows – including streamlined submission of clinical documentation – reducing administrative burden and improving speed and accuracy. HHS proposes that HIPAA covered entities (health care providers, health plans, and health care clearinghouses) that engage in those electronic transactions would be required to comply with these proposals no later than 24 months after the final rule’s effective date.
- Impact on Hospice Providers:
While the primary focus is on managed care and exchange plans, CMS has noted that improvements in electronic health information exchange, such as FHIR APIs for data access, can support better care coordination for beneficiaries, including those receiving hospice services. - Impact on Home Health Providers
- Reduced Administrative Burden: The shift to electronic, API-driven workflows reduces the time staff spend on telephone calls and faxes for prior authorizations.
- Faster Patient Care: Quicker turnaround on authorization decisions allows home health providers to start services faster, reducing delays in patient care.
- Improved Transparency: Electronic denials with detailed reasons help providers understand why a service was denied, leading to better compliance and fewer, more efficient appeals.
- Interoperability Challenges: Providers must adopt ONC-certified health information technology to leverage these new APIs for faster, automated processing.
- Impact on DMEPOS Providers
- Streamlined PA Processes: Payers must implement electronic PA capabilities, allowing providers to submit requests and receive decisions directly through their electronic health records (EHRs).
- Faster Decisions: Beginning in 2026, many plans must send PA decisions within 72 hours for expedited requests and 7 days for standard requests, with tighter 24-hour windows for certain drug requests.
- Reduced Burden: The rules are designed to decrease the administrative burden of traditional, paper-based, or portal-heavy PA processes, which can speed up the approval process for durable medical equipment (DMEPOS).
- Increased Transparency: Payers must provide specific reasons for denied requests, facilitating better appeal processes for providers.
- Impact on Workflows: DMEPOS providers must transition to using API-enabled systems to take advantage of the faster, electronic PA processes
To view the proposed rule on the Federal Register, visit: https://www.federalregister.gov/public-inspection/2026-07205/medicare-and-medicaid-programs-patient-protection-and-affordable-care-act-interoperability-standards.
To view the fact sheet, visit: https://www.cms.gov/newsroom/fact-sheets/2026-cms-interoperability-standards-prior-authorization-drugs-proposed-rule
CMS updated the 2026 CMS Interoperability Standards and Prior Authorization for Drugs Proposed Rule (CMS-0062-P) webpage with related resources to help you learn more, including:
- Federal Register link to the rule: Submit comments by June 15
- Fact sheet
- Press release
- Technical workflows: Visual guides to assist with the technical implementation of the proposed National Council of Prescription Drug Programs standards and existing Payer-to-Payer and Prior Authorization Application Programming Interfaces
- Proposed metrics summary: Detailed information regarding the new proposed reporting metrics
- Summary of proposed provisions: High-level overview of the key proposals introduced in the rule
- Town Hall presentation and recording (April 16, 2026)
CMS Posts Proposed Rule: Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2027 Rates; Requirements for Quality Programs; and Other Policy Changes
CMS issued a proposed rule that would update Medicare payment policies and rates for inpatient and long-term care hospitals under the Medicare hospital Inpatient Prospective Payment System (IPPS) and Long-Term Care Hospital Prospective Payment System (LTCH PPS) for fiscal year (FY) 2027. The proposed rule also includes proposed changes, clarifications, and codifications for Organ Acquisition and Reasonable Cost Payment Policies, and Reimbursement Appeals for Independent Organ Procurement Organizations and Histocompatibility Laboratories.
The proposed rule would update Original Medicare payment rates and policies for inpatient hospitals and LTCHs for FY 2027. CMS is publishing this proposed rule to meet the legal requirements to update Medicare payment policies for IPPS hospitals and LTCHs on an annual basis
CMS is proposing to adopt the Advance Care Planning electronic clinical quality measure (eCQM) in the Hospital Inpatient Quality Reporting, PPS-Exempt Cancer Hospital (PCH) Quality Reporting, and Medicare Promoting Interoperability Programs. We are proposing to adopt five modified claims-based, risk-standardized mortality measures in the Hospital Inpatient Quality Reporting Program and subsequently modify these measures in the Hospital Value-Based Purchasing Program.
- Impact on Hospice Providers
While the primary focus is IPPS/LTCH, the rule affects how acute care hospitals handle patient transfers to hospice and other post-acute settings, which are monitored under quality measures.
- Home Health Impact
The proposed rules emphasize strengthening value-based care and improving transitions between acute settings (hospitals/LTCHs) and post-acute settings, such as home health, aimed at reducing readmissions and aligning with the overarching goal of reducing total cost of care.
To view the proposed rule on the Federal Register, visit: https://public-inspection.federalregister.gov/2026-07203.pdf
To view the fact sheet, visit: https://www.cms.gov/newsroom/fact-sheets/fy-2027-hospital-inpatient-prospective-payment-system-ipps-long-term-care-hospital-prospective
Hospice/Palliative Care Provider Updates
Hospice Levels of Care & How to Bill for Service Intensity Add-On Payments
CMS posted a new video to educate hospices on service intensity add-on payments. This allows you to bill for additional registered nurse and social worker visits during the last 7 days of a patient’s life in addition to the standard daily reimbursement.
Visit the Hospice Center webpage for more information.
Home Health Provider Updates
Expanded HHVBP Model: Preliminary April 2026 Interim Performance Reports (IPRs) are Available in iQIES
Preliminary April 2026 Interim Performance Reports (IPRs) are Available in iQIES
The Preliminary April 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 based on measure-specific 12-month and 24-month reporting periods, 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.
An HHA receives an April 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: April 2026 IPR quality measure performance time periods by measure category
| Measure Category | Time Period | Minimum Data Threshold |
| OASIS-based | Jan 1, 2025 – Dec 31, 2025 | 20 home health quality episodes |
| Claims-based | DTC-PAC: Oct 1, 2023 – Sep 30, 2025 PPH: Oct 1, 2024 – Sep 30, 2025 | 20 home health stays |
| HHCAHPS Survey-based* | Oct 1, 2024 – Sep 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.”
Please also refer to the updated Expanded HHVBP Model IPR Quick Reference Guide (PDF) available on the Expanded HHVBP Model webpage. This resource outlines the types of data included, eligibility criteria, how interim performance scores are calculated, and the process for submitting recalculation requests. This easy-to-scan two-pager provides all the key details to stay aligned with HHVBP performance expectations.
Looking Ahead to the CY 2026 Applicable Measure Set
As outlined in the CY 2026 Home Health (HH) Prospective Payment System (PPS) Final Rule, there are changes to the expanded HHVBP Model applicable measure set starting with CY 2026 (referred to as the “CY 2026 measure set”). The October 2026 IPRs will be the first IPRs to generate improvement, achievement, and care points based on the CY 2026 applicable measure set. To help HHAs get ready for this change, CMS has started providing a preview of HHAs’ performance on the CY 2026 measure set. Specifically, starting with the October 2025 IPRs, achievement thresholds (AT) and benchmarks (BM) (see “CY 2026 AT and BM” tab) and HHA’s improvement thresholds for the CY 2026 measure set are available to HHAs in each IPR.
Important Update on Corrected Risk Adjustment Processing
CMS recently determined that the risk adjustment coefficient values for home health (HH) episodes with start of care (SOC) or resumption of care (ROC) completion dates (M0090) on or after January 1, 2025 that were released to the public in 2025 had not been implemented in iQIES HH measure calculations (see HHQRP QM Risk Adjustment Technical Specifications 2026 (PDF), “Downloads” section at Home Health Quality Measures | CMS). Instead, OASIS-based measures for these HH episodes were calculated using the risk adjustment models developed for home health episodes with SOC/ROC completion dates between January 1, 2024 and December 31, 2024 only. The impacted HH episodes with SOC/ROC completion dates between January 1, 2025 and December 31, 2025, were used to calculate a portion of performance measures reported in the following performance reports:
- July 2025 Interim Performance Reports (IPRs) (Q1 2025)
- October 2025 IPRs (Q1-Q2 2025)
- January 2026 IPRs (Q1-Q3 2025)
A correction for this processing issue was deployed in iQIES in early April 2026 and is reflected starting with the April 2026 IPRs. Note that this necessary correction is limited to HH episodes with SOC/ROC completion dates in CY 2025.
In sum, the HHQRP 2025 QM Manual and Risk Adjustment Technical Specifications presented the correct risk adjustment values that were intended for use with HH episodes SOC/ROC completion dates in calendar year 2025, whereas implementation in iQIES had to be corrected to align with the documentation.
To assess the implications of this processing issue on publicly reported performance, CMS completed an impact analysis by comparing OASIS-based measure values that were incorrectly risk-adjusted with 2024 risk adjustment coefficients as reported in Risk Adjustment Technical_Specifications_2024 (PDF) with OASIS-based measure values that were correctly risk-adjusted using 2025 risk adjustment coefficients as reported in the HHQRP QM Risk Adjustment Technical Specifications 2025 (PDF). This analysis used a CY 2025 reporting period based on HH episodes ending in CY 2025. Overall, analysis results showed small changes in agency-level OASIS-based measure scores. There were also very small changes to agency-level relative measure performance rankings for agencies with at least 20 eligible HH episodes to generate a measure value.
DMEPOS Updates
Manual Wheelchairs: Prevent Claim Denials
In 2024, the improper payment rate for manual wheelchairs was 30.5%, with a projected improper payment amount of $28.1M. Learn how to bill correctly for these services. Review the Manual Wheelchairs provider compliance tip for more information, including:
- Billing codes
- Denial reasons and how to prevent them
- Documentation requirements
DMEPOS Therapeutic Shoes: Document Qualifying Conditions
Industry asked CMS to clarify our requirement to document the presence of the qualifying condition(s) necessary for payment of therapeutic shoes. There are 2 longstanding options to meet that requirement:
- Personal documentation by the certifying physician in their own medical records, or
- Co-signed notes of the podiatrist or other physician or practitioner
More Information:
- Therapeutic Shoes for Persons with Diabetes Local Coverage Determination
- Therapeutic Shoes for Persons with Diabetes Policy Article
- Therapeutic Footwear provider compliance tip
Lower Limb Orthoses: Prevent Claim Denials
In 2024, the improper payment rate for lower limb orthoses was 35.2%, with a projected improper payment amount of $91.2M. Learn how to bill correctly for these services. Review the Lower Limb Orthoses provider compliance tip for more information, including:
- Billing codes and criteria
- Denial reasons and how to prevent them
- Coverage and payments
- Documentation requirements
- Resources
All Providers Updates
CMS & FDA Announce RAPID Coverage Pathway to Accelerate Patient Access to Life-Changing Medical Devices
CMS and the FDA announced the Regulatory Alignment for Predictable and Immediate Device (RAPID) coverage pathway, a new pathway designed to expedite access to certain FDA-designated Class II and Class III Breakthrough Devices for people with Medicare.
Read the full press release.
HCPCS Application Summaries & Coding Determinations: Drugs & Biologicals
CMS published the 2026 HCPCS Application Summary for Quarter 1, 2026 Drugs and Biologicals. Visit the HCPCS Level II Coding Decisions webpage for more information.
Fix Death Date Errors in Medicare Records
Sometimes Medicare records incorrectly show that a patient has died, or the records list the wrong date of death. When this happens, Medicare will not pay the claim until we get a correction. Learn about (PDF):
- Where these errors come from
- How to fix incorrect dates of death
ACCESS Model Application Period Extended, First Applicants Accepted to Join
More than 150 leading health care organizations have been accepted to participate in the launch of the ACCESS (Advancing Chronic Care with Effective Scalable Solutions) Model. Most of the organizations have not previously served Medicare beneficiaries and will bring additional technology-supported care options to help people manage chronic conditions like high blood pressure, diabetes, chronic pain and depression.
What to expect: CMS is extending the initial application deadline to May 15, 2026, so that more organizations can participate in ACCESS when it launches on July 5, 2026; Medicare enrollment is required for participation but not to apply.
Additional details: The voluntary ACCESS Model focuses on conditions affecting more than two-thirds of people with Medicare. All organizations must adhere to strict guardrails, which include enrollment in the Medicare Part B as providers or suppliers, compliance with licensure, data privacy and security standards, outcome-reporting, and other quality standards. Private payers representing 165 million members across Medicare Advantage, Medicaid, and commercial coverage have also committed to aligning with the ACCESS model’s payment approach, with many beginning this year.
For a list of accepted applicants, visit: https://www.cms.gov/priorities/innovation/access-model-accepted-applicants
Find out more:
Educational Opportunities
CCSQ Quarterly Stakeholder Webinar – May 12
Tuesday, May 12 from 12–1 pm ET
Register for this webinar.
You’re invited to join Dr. Dora Hughes, Chief Medical Officer of CMS and Director of the Center for Clinical Standards and Quality (CCSQ), and the CCSQ leadership team for an engaging update on our work to strengthen health care quality, safety, and coverage. Hear the latest on recent policy developments and how these efforts are accelerating progress toward improving care and outcomes for beneficiaries in Medicare, Medicaid, and the Marketplace.
HCPCS Public Meeting – June 1–2
Monday, June 1 and Tuesday, June 2 from 9 am – 5 pm ET
Attend a hybrid public meeting for the first biannual 2026 HCPCS coding cycle. Visit HCPCS Level II Public Meetings for more information, including:
- Meeting materials
- Guidelines
2026 CMS & HL7 Virtual FHIR Connectathon
The Centers for Medicare & Medicaid Services (CMS) is excited to announce the 7th annual CMS & Health Level Seven International (HL7®) Fast Healthcare Interoperability Resources (FHIR®) Connectathon, taking place July 14-16, 2026. This virtual collaborative experience will bring together health care interoperability leaders, implementers, and innovators for three days of hands-on testing, shared learning, and alignment on how emerging CMS policies and FHIR-based solutions are taking shape in real-world systems.
How to Participate:
Additional details, including registration, track list, and full agenda will be available soon.
To learn more about the event and ways to participate, please contact: CMSInteroperability@cms.hhs.gov.