What does the 2027 home health final rule change for your agency?

The base rate rises about 2.7%, more than the 2.1% update, because CMS raised it a little so that resetting the payment-group weights and the wage index doesn't change total Medicare spending.

On $5 million of Medicare fee-for-service revenue, the average would mean about $120,000 more in 2027, if your volume and patient mix held steady.

The biggest swing in CMS's estimates comes from the wage index, which adjusts pay for local wages. Agencies in Alabama, Kentucky, Mississippi and Tennessee average 1.6%, the lowest of any region. Agencies in New Jersey, New York and Pennsylvania average 3.6%, the highest. On the same $5 million, that's roughly $80,000 against $180,000. Freestanding for-profit agencies, 8,598 of the 10,082, average 2.3%.

CMS keeps the 5% cap on wage index drops. Some counties that needed a wage index transition code on claims in 2025 and 2026 won't need one in 2027, and the list is a tab in CMS's 2027 wage index file.

Don't budget from the base rate. It rises about 2.7%, but CMS also reset the case-mix weights, and your payment is the base rate times your patients' weights. Budget from your own payment groups' new weights, in table 11 of the final rule (91 FR 72052 to 72061) and CMS's case-mix weight file.

Miss quality reporting and your update drops from 2.1% to 0.1%. On $5 million, that's about $100,000.

CMS says payments from 2020 through 2025 ran higher than they would have under the old payment system, because agencies changed how they coded and billed after the switch to 30-day periods. It puts that overpayment at about $4.9 billion, and the 3% cut in 2027 takes back about $500 million of it, roughly a tenth.

Because 2026 had the same cut, CMS's 2027 tables show it as zero change, but it still lowers your rate: without it, the 2027 base rate would be $2,157.41 instead of $2,092.69.

CMS also worked out a further permanent cut for 2027, -3.793%, and chose not to apply it this year, so it could still come back in a later rule.

Check your most common payment groups against the table below, and if a big one moved, make sure visit plans still fit what those patients need. To find them, run your billing system's report of 30-day periods by HIPPS code (the five-character payment group code, like 1GB21), or read the codes on your paid Medicare claims. A 30-day period with fewer visits than its group's LUPA threshold is paid per visit instead of the full period amount. Per-visit rates rise 2.1%, and the rule applies neither the temporary nor the permanent cut to them.

CMS reset the thresholds for all 432 payment groups using 2025 claims. By our count of CMS's 2026 and 2027 files, 38 groups move by exactly one visit: 23 drop and 15 rise. If you've seen "ten groups down, one up" from the rule, that is a different comparison from ours, by our reading: the rule says its proposed data showed 18 one-visit drops and newer data cut the final count to 10.

A group that drops a visit sends fewer of its periods to per-visit pay. A group that adds one sends more.

CMS also updated the points each answer earns on the OASIS items about daily activities like bathing, dressing and walking (M1800 to M1860) and about risk of hospitalization (M1033), and the cutoffs between low, medium and high functional levels. In the "MMTA - Other" clinical group, for example, high now starts at 43 points, down from 46 in 2026 (2027 final rule, table 7, 91 FR 72041; 2026 final rule, Table 9). So the same patient can land in a different functional level, and a different payment group, in 2027.

CMS lowered the bar a period's costs must clear to earn an outlier payment. More high-cost periods will qualify for an outlier payment, though CMS says the payment per period has to be lower, and CMS expects the change to add 0.3%, about $50 million.

### The new deadlines

Starting with 2027 data, OASIS assessments, corrections included, are due by the 15th day of the second month after each quarter ends. For 2027 that's May 17, August 16 and November 15, 2027, and February 15, 2028. The first two aren't the 15th because May 15 is a Saturday and August 15 a Sunday: the rule moves a deadline that lands on a Friday, weekend or federal holiday to the next business day.

Until now you had about four and a half months after each quarter. Now it's about 45 days. Most agencies already submit in time: CMS found 99.27% of 2024 assessments arrived within about 45 days. The window to correct them is what shrinks, so an error your team finds three months after a quarter closes misses the cutoff for the data CMS uses.

### The 90% bar moves to the calendar year

The yearly requirement to submit at least 90% of required OASIS assessments now runs January through December. During the switch, the check for your 2028 payment update rests on OASIS data from July 1 to December 31, 2026, and HHCAHPS survey data from April 1 to December 31, 2026, so the months you're in now already count.

### If CMS says you missed a requirement

The noncompliance notice still comes by mail and through CMS's data submission system, but CMS's decision on a reconsideration request now comes only through that system. You have 30 calendar days from the date on the notice to ask for reconsideration, so someone on your team needs to be watching that system.

### Value-based purchasing

Value-based purchasing, the program that raises or lowers your Medicare pay based on your quality scores, doesn't change. Your 2027 results set your 2029 adjustment.

If you're buying or selling an agency, or bringing in a management company, check the timing with your lawyer first. An agency whose majority ownership changes within 36 months of its first Medicare enrollment, or of its last ownership change, already has to enroll as a new agency and go through a new survey. The rule now lets CMS deny or revoke enrollment when an agency doesn't.

The rule names management agreements used to hand over control before a sale as one way agencies have gotten around the 36 months. And an ownership change that needs a new enrollment is now caught by any enrollment freeze in place. CMS says these enrollment changes are effective January 1, 2027, the same day as the payment changes (91 FR 72133). The rule's dates line prints a different date for them, January 4, 2026, so confirm the start with your Medicare contractor before you plan a sale around it.

Here's what we'd do now:

1. Ask your billing or EHR vendor when the 2027 rates, weights and LUPA thresholds go in, and whether they've run test claims through CMS's 2027 grouper, the software that assigns each period to its payment group.
2. If you bill with a wage index transition code, check your counties against CMS's 2027 list.
3. Set an internal OASIS correction date about 30 days after each quarter ends, so May 17 isn't the first time anyone looks.
4. By December 31, check your OASIS submission rate since July 1 against the 90% bar, and confirm your HHCAHPS survey data covers every month since April 1.

Enzo is a home health EHR. With less time to correct OASIS data, catching errors before a chart is submitted matters more. Enzo Scribe builds OASIS-ready notes from the visit conversation, and Enzo QA checks diagnosis codes, comorbidities and OASIS responses on every chart before it's submitted. Both are part of Enzo's EHR, along with Intake, which reads the full referral package. Intake, Scribe and QA also connect to your existing EHR. Ask us how they connect to yours.

• Centers for Medicare & Medicaid Services, "Calendar Year (CY) 2027 Home Health Prospective Payment System Final Rule - CMS-1844-F," fact sheet, November 4, 2026: https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2027-home-health-prospective-payment-system-final-rule-cms-1844-f
• Centers for Medicare & Medicaid Services, "Calendar Year 2027 Home Health Prospective Payment System (HH PPS) Rate Update," final rule CMS-1844-F, 91 FR 72022 to 72173, Federal Register document 2026-22750, November 9, 2026: https://www.federalregister.gov/d/2026-22750
• Centers for Medicare & Medicaid Services, "CY 2027 Final HH PDGM Case Mix Weights and LUPA Thresholds," CMS-1844-F rule page, November 4, 2026: https://www.cms.gov/medicare/payment/prospective-payment-systems/home-health/home-health-prospective-payment-system-regulations-and-notices/cms-1844-f
• Centers for Medicare & Medicaid Services, "CY 2027 Proposed HH PDGM Case-Mix Weights and LUPA Thresholds," CMS-1844-P rule page, July 1, 2026: https://www.cms.gov/medicare/payment/prospective-payment-systems/home-health/home-health-prospective-payment-system-regulations-and-notices/cms-1844-p
• Centers for Medicare & Medicaid Services, "CY 2026 Final HH PDGM Case Mix Weights and LUPA Thresholds," CMS-1828-F rule page, November 28, 2025: https://www.cms.gov/medicare/payment/prospective-payment-systems/home-health/home-health-prospective-payment-system-regulations-and-notices/cms-1828-f
• Centers for Medicare & Medicaid Services, "Calendar Year 2026 Home Health Prospective Payment System (HH PPS) Rate Update," final rule CMS-1828-F, Federal Register document 2025-21767, December 2, 2025: https://www.federalregister.gov/d/2025-21767
• Centers for Medicare & Medicaid Services, "Calendar Year (CY) 2026 Home Health Prospective Payment System Final Rule (CMS-1828-F)," fact sheet, November 28, 2025: https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2026-home-health-prospective-payment-system-final-rule-cms-1828-f