CMS Releases FY 2027 LTCH Prospective Payment System Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service (FFS) long-term care hospital (LTCH) prospective payment system (IPPS) for fiscal year (FY) 2027. Highlights of the proposed rule include:

  • Increasing the standard LTCH PPS rate by a net 2.7%, after the 0.8 productivity cut and budget neutrality adjustments, from $50,824 to $52,177 for LTCHs that successfully comply with the CMS quality reporting program and electronic health record requirements. LTCHs that do not meet the requirements for these programs are subject to a 2-percentage-point reduction in the annual update.
  • Continue paying cases at the site-neutral rate if they fail to meet LTCH criteria.
  • Maintaining the fixed-loss amount for high-cost outlier cases at the current $78,936 for standard LTCH payment rate cases. Site-neutral payment cases are subject to the inpatient PPS fixed loss amount, proposed at $51,679.
  • Increasing the labor-related share of the standardized operating rate slightly from 72.9% to 73%
  • Removing two measures from the LTCH Quality Reporting Program (QRP) and from public display beginning with the FY 2028 payment determination. If finalized, LTCHs would not be required to report calendar year 2026 data for the COVID-19 Vaccination Coverage Among Healthcare Personnel measure. The CMS also proposes to remove the COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date measure beginning with the FY 2028 payment determination.
  • Revising the LTCH QRP data submission deadlines beginning with the FY 2029 LTCH QRP to reduce the timeframe for data submission from four and a half months after the end of the performance period to 45 days.

The MHA will provide a hospital-specific impact analysis and additional details in the coming weeks. Members are encouraged to submit comments to CMS by June 9 and notify Vickie Kunz at the MHA of any identified issues by June 1. CMS is expected to release a final rule around Aug. 1.

CMS Releases FY 2027 Hospital Inpatient Prospective Payment System Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service (FFS) inpatient prospective payment system (IPPS) for fiscal year (FY) 2027. Highlights of the proposed rule include:

  • Mandating participation in the expanded Comprehensive Joint Replacement Model by all acute care hospitals paid under the inpatient prospective payment system beginning Oct. 1, 2027, for beneficiaries undergoing lower extremity joint replacements in the inpatient or outpatient setting.
  • Increasing the standardized operating rate by a net 3.2%, after a 0.8% productivity cut and budget neutrality adjustments, from $6,752.61 to $6,967.87 for hospitals that successfully comply with the CMS quality reporting program and electronic health record requirements. Hospitals that do not meet these requirements are subject to a reduced annual update.
  • Increasing the federal capital rate by 4%, from $524.15 to $545.22.
  • Increasing the cost outlier threshold by 28%, from $40,397 to $51,704, to maintain the target of paying 5.1% of aggregate inpatient prospective payment system payments as outliers.
  • Maintaining the current labor-related share of the standardized operating rate at 66% for hospitals with a wage index greater than 1.0 and 62% for those with a wage index equal to or less than 1.0.
  • Decreasing disproportionate share hospital and uncompensated care payments by $564 million nationally. Uncompensated care payments will be allocated using the average of the three most recent years of audited Worksheet S-10 data.
  • Updating Medicare Severity-Diagnosis Related Group relative weights using FY 2025 MedPAR claims data and updated cost report and cost-to-charge ratios.
  • Adding 14 new Medicare Severity Diagnosis-Related Groups while deleting 18, with most changes within Major Diagnostic Category 05, Diseases and Disorders of the Circulatory System; Major Diagnostic Category 08, Diseases and Disorders of the Musculoskeletal System and Connective Tissue; and Major Diagnostic Category 13, Diseases and Disorders of the Female Reproductive System.
  • Modifying off-campus provider-based location rules by changing the “same patient population” criteria. Specifically, CMS proposes limiting the referral-based 75% test to outpatient departments only. Inpatient facilities seeking provider-based status could continue using the alternative ZIP code overlap test, but would no longer be allowed to use the referral-based test to meet the location requirement.
  • Adopting eight measures for the Hospital Inpatient Quality Reporting Program, including 3 measures not previously used in CMS quality programs:
    • Excess Days in Acute Care After Hospitalization for Diabetes
    • Advance Care Planning
    • Hospital Harm – Postoperative Venous Thromboembolism
  • Adopting one measure on sepsis readmissions for the Hospital Readmissions Reduction Program for the FY 2029 program year.

The MHA will provide a hospital-specific impact analysis and additional details on the proposed rule in the near future. Members are encouraged to submit comments to CMS by June 9 and to notify Vickie Kunz of any issues identified by June 1.  The CMS is expected to release a final rule around Aug. 1.

CMS Releases FY 2027 Skilled Nursing Facilities Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service (FFS) prospective payment system for skilled nursing facilities (SNFs) for fiscal year (FY) 2027. Key provisions of the proposed rule include:

  • Increasing the per diem federal rate by a net 2.3% after the market basket update, productivity adjustment and other adjustments. Facilities that fail to meet quality reporting requirements will be subject to a two-percentage-point reduction to the market basket update.
  • Updating the labor-related share of the per diem rate from 71.9% to 72%.
  • Continuing to use pre-reclassification and pre-floor hospital inpatient prospective payment system wage indexes while soliciting input on alternative data sources, such as Bureau of Labor Statistics data, for the wage index.
  • Removing two measures focused on COVID-19 vaccination for patients and healthcare personnel
  • Shortening the timeframe for quarterly submission of Minimum Data Set and National Healthcare Safety Network data from 4.5 months to 45 days, beginning with fiscal year 2029. For example, data for the quarter ending March 31, 2027, would be due to CMS by May 17, 2027.
  • Requiring submission of Minimum Data Set data for all residents receiving skilled care, regardless of payer, for patients admitted on or after Oct. 1, 2029.
  • Updating the dates used for calculating two value-based purchasing program measures: discharge function and falls with major injury.
  • Requesting information on potential updates to the Patient-Driven Payment Model.

The MHA will provide facilities with a facility-specific impact analysis and additional details on the proposed rule in the coming weeks. Members are encouraged to submit comments to the CMS by June 1 and notify Vickie Kunz at the MHA of any issues identified by May 22.

CMS Releases FY 2027 Inpatient Rehabilitation Facilities Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service (FFS) prospective payment system for inpatient rehabilitation facilities (IRF) for fiscal year (FY) 2027.

Key provisions of the proposed rule include:

  • Increasing the inpatient rehabilitation facilities’ prospective payment system payment rate by a net 2.6% after all adjustments, from $19,371 to $19,881. Facilities that fail to comply with CMS quality reporting requirements are subject to a two-percentage-point reduction.
  • Using fiscal year 2025 claims and fiscal year 2024 cost report data to update case mix group weights and average lengths of stay.
  • Increasing the labor-related share from 74.4% to 74.5%.
  • Continuing to use pre-reclassification and pre-floor hospital inpatient prospective payment system wage indexes while soliciting input on alternative data sources, such as Bureau of Labor Statistics data, for the wage index.
  • Decreasing the cost outlier threshold by 14.3%, from $10,141 to $8,689, to achieve the 3% target for outlier payments compared with aggregate payments.
  • Updating and clarifying coverage rules, including:
    • Requiring all therapies to be initiated within 36 hours of admission, with therapy evaluations qualifying as initiation under this clarification.
    • Requiring preadmission screening documentation to include the patient’s current functional status upon admission.
    • Requiring the initial interdisciplinary team meeting to occur within four days of admission, with subsequent meetings held weekly.
  • Shortening the timeframe to submit quality reporting data following the end of each quarter from 4.5 months to 45 days, beginning with fiscal year 2029. For example, data from the quarter ending March 31, 2027, would be due to CMS by May 17, 2027.
  • Requesting information on modernizing the prospective payment system, including replacing the current system with new clinical categories and comorbidity score groupings.

The MHA will provide facilities with a facility-specific impact analysis and additional details on the proposed rule in the near future. Members are encouraged to submit comments to CMS by June 1 and notify Vickie Kunz of any issues identified by May 22.

CMS Releases FY 2027 Inpatient Psychiatric Facilities Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service prospective payment system for inpatient psychiatric facilities (IPF) for fiscal year (FY) 2027.

Key provisions of the proposed rule include:

  • Increasing the IPF prospective payment system (PPS) federal per diem base rate by a net 2.2% after all adjustments, from $892.87 to $912.58 for IPFs that comply with the CMS IPF Quality Reporting Program (QRP) requirements. The rate for providers that fail to report quality data is $894.74.
  • Increasing the electroconvulsive therapy payment per treatment by a net 2.2% from $673.85 to $688.73 for IPFs that comply with IPF QRP requirements and $675.26 for IPFs that fail to report data.
  • Increasing the labor-related share from the current 79% to 79.1%.
  • Continuing to use the pre-reclassification and pre-floor hospital inpatient PPS wage indexes while soliciting input on alternative data sources, such as Bureau of Labor Statistics data for the IPF wage index.
  • Decreasing the cost outlier threshold by 3.9%, from $39,360 to $37,820, to achieve the 2% target for outlier payments compared with aggregate payments.
  • Limiting total outlier payments to no more than 20% of a facility’s total payments. If finalized, facilities that exceed this cap would no longer receive outlier payments.
  • Updating the IPF QRP to:
    • Remove two measures:
      • Alcohol Use Brief Intervention Provided or Offered and Alcohol Use Brief Intervention (SUB-2/2a) measure.
      • Tobacco Use Treatment Provided or Offered at discharge (TOB-3/3a) measure.
    • Implement the IPF-Patient Assessment Instrument (IPF-PAI) to collect and submit certain standardized patient assessment data beginning Oct. 1, 2027, for the FY 2029 payment determination. The CMS proposes two methods for IPF-PAI data submission: a free CMS-developed web application or two Fast Healthcare Interoperability Resource (FHIR) application programming interfaces. This would be the first time the CMS would include data submission via the FHIR standard in a QRP.

The MHA will provide facilities with a facility-specific impact analysis and additional details on the proposed rule in the coming weeks.  Members are encouraged to submit comments to the CMS by June 1 and notify Vickie Kunz at the MHA of any issues identified by May 22.

CMS Releases 2025 Occupational Mix Survey for Hospitals

The Centers for Medicare & Medicaid Services (CMS) recently released the 2025 occupational mix survey to collect data from hospitals paid under the Medicare inpatient prospective payment system. Survey results will be used to adjust the Medicare area wage index for fiscal years 2028, 2029 and 2030. Completed surveys must be submitted to the hospital’s Medicare Administrative Contractor (MAC) on the Excel reporting form by June 30, 2026, and must be submitted to the MAC via email.

The MHA hosted an educational webinar in June 2025, and members may request access to the materials and recording by contacting Crystal Mitchell at the MHA.

Members with questions should contact Vickie Kunz at the MHA.

MHA Monday Report Dec. 8, 2025

Stop the Bleed Legislation Advances, Preadmission Screening Bill Introduced

Legislation protecting good Samaritans who apply bleeding-control techniques passed the Senate Civil Rights, Judiciary and Public Safety Committee, while a bill modifying timeline requirements for preadmission screening assessments of Medicaid patients was introduced during the …


CMS Releases 2026 Home Health PPS Final Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule updating the home health prospective payment system (PPS) for calendar year 2026. Highlights of the rule include: An updated 30-day …


MDHHS Launches RHTP Listserv to Share Program Updates

The Michigan Department of Health and Human Services (MDHHS) recently launched a Rural Health Transformation Program (RHTP) listserv to provide timely updates, announcements and resources related to the state’s implementation of the program. Hospitals, health …


Health Access & Community Impact Office Hours Launch

The MHA Health Access & Community Impact Office Hours series kicked off Nov. 24 with a session highlighting 211 and its role in addressing food access amid ongoing challenges related to food insecurity. Sarah Kile, …


Nominations Open for 2026 Michigan Hometown Health Hero Awards

The Michigan Public Health Week Partnership, a coalition of 13 statewide organizations that include the MHA, is seeking nominations by Friday, Dec. 19, for individuals and organizations that have contributed to improving the health and …


MHA Rounds graphic of Brian PetersMHA CEO Report — Dedicated to Care Every Day of the Year

During the holiday season, we look forward to annual traditions and time spent with loved ones. While many of us gather around our tables this season, we are all aware of individuals who sacrifice this special time …


Centering Lived Experiences to Improve Maternal Care: Reflections from the Birth Experience Project

Over the past year, I supported the Birth Experience Project, a mixed-methods study examining how Black women across Michigan experience pregnancy, labor and delivery, and postpartum care. As part of this effort, I assisted in analyzing …


Keckley Report

The 10 Healthcare Headlines you Might See in 2026

“2026 is a mid-term election year. In 2016 (Trump 45 Year One), Republicans controlled 31 governorships and 68 legislative chambers. This January, the GOP will control 26 governorships and 57 legislative chambers– a 15% reduction on both. Politics is divided, affordability matters most to voters and healthcare is a high-profile target for campaigns so humility, thoughtful messaging backed by demonstrable actions will be an imperative for every healthcare organization.

2026 is a HUGE year for U.S. healthcare. The outcome is unknown.”

Paul Keckley, Nov. 23, 2025

CMS Releases 2026 Home Health PPS Final Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule updating the home health (HH) prospective payment system (PPS) for calendar year (CY) 2026.

Highlights of the rule include:

  • An updated 30-day episode payment rate of $2,038.22, comprised of a net 2.4% market basket update, a 3.6% reduction due to budget neutrality requirements of the Patient-Driven Groupings Model (PDGM) and other budget neutrality adjustments. The 2026 rate is down 0.1% from the current $2,057.35. Providers who fail to submit quality data are subject to an additional two percentage point reduction.
  • A fixed-dollar loss ratio of 0.37, up from 0.35, with the CMS maintaining the existing 0.8 loss-sharing ratio.
  • Recalibrated PDGM case mix weights based on CY 2024 data; updated low-utilization payment adjustment thresholds, updated functional impairment levels and comorbidity adjustment subgroups.
  • Modifying the face-to-face encounter restriction to allow physicians and non-physician practitioners to perform the face-to-face encounter, regardless of whether they are the certifying physician or previously cared for the patient.
  • Updating the HH quality reporting program (QRP) to remove the measure that assesses the percentage of patients receiving COVID-19 vaccinations and the corresponding outcome and assessment information set data element. The CMS is also removing four patient assessment data elements related to social drivers of health from the HH QRP. These measures include one living situation item, two food items and one utilities item.
  • Adding four new measures to the HH value-based purchasing program, Medicare Spending per Beneficiary, and three measures assessing patient functional improvement in dressing and bathing.
  • Adopting several new and revised provider enrollment provisions that the CMS believes will help reduce improper Medicare payments and protect beneficiaries.

The MHA will provide members with an updated impact analysis in the next several weeks. Members with questions should contact Vickie Kunz at the MHA.

News to Know – Nov. 24, 2025

New to Know
  • New to KnowThe Centers for Medicare & Medicaid Services recently announced 2026 premiums, deductibles and coinsurance amounts for Medicare Parts A and B. Members with questions may contact Vickie Kunz at the MHA.
  • The MHA offices will be closed and no formal meetings will be scheduled Nov. 27 and 28 in honor of Thanksgiving.
  • Due to the holiday, Monday Report will not be published Dec. 1 and will resume its regular schedule Dec. 8. Member alerts and MHA newsroom articles will continue to be published during that time to provide relevant updates to the MHA membership, as necessary.
  • The American Hospital Association (AHA) released the first three chapters of its 2025 National Governance Report. The report, based on data collected from August to December 2024, outlines a comprehensive picture of healthcare governance structures and practices across the country in areas including composition, performance oversight and selection. The report includes commentary from governance experts to provide valuable insights into the data and trends presented. Questions about the AHA National Governance Report or governance can be directed to Erin Steward at the MHA.

CMS Releases CY 2026 Physician Fee Schedule Final Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the physician fee schedule for calendar year (CY) 2026.

Highlights of the final rule include:

  • Implementing the one-time 2.5% statutory increase included in H.R. 1.
  • Establishing two separate conversion factors: one for qualifying alternative payment model participants (QP) and another for non-qualifying physicians and practitioners.
    • The QP conversion factor would increase by 3.8% to $33.58.
    • The non-QP conversion factor would increase by 3.3% to $33.40.
  • Modifying several telehealth waivers, including:
    • Permanently removing the frequency limitations for subsequent inpatient visits, nursing facility visits and critical care consultations.
    • Permanently adopting a definition of direct supervision to include virtual presence via audio/video real-time communications technology.
    • Permanently allow teaching physicians to have a virtual presence for services involving residents across all training locations when the service is performed virtually.
    • Extending the ability for federally qualified health centers and rural health clinics to bill telehealth services through Dec. 31, 2026.
  • Enhancing integration of behavioral health into primary care by:
    • Clarifying that marriage and family therapists, and mental health counselors, can bill Medicare directly for community health integration and principal illness navigation services.
    • Creating add-on codes for advanced primary care management services that complement previously established Behavioral Health Integration or psychiatric Collaborative Care Model services.
    • Retaining the Healthcare Common Procedure Coding System code that describes social determinants of health risk assessment and revising its descriptor to refer to “upstream drivers” of health rather than “social determinants.”
  • Creating a new claims-based methodology to remove units of drugs purchased under the 340B program for purposes of calculating Medicare drug inflation rebates starting Jan. 1, 2026. The claims-based methodology uses existing data files for these linkages and does not require 340B-covered entities to submit any additional data. The CMS also finalized its proposal to create a 340B claims data repository, allowing voluntary data submission by 340B providers for potential use in the same purpose.
  • Implementing the Ambulatory Specialty Model, a mandatory alternative payment model within selected core-based statistical areas, focused on specialists who care for beneficiaries with heart failure and low back pain, to begin Jan. 1, 2027, and run for five years through Dec. 31, 2031.
  • Establishing a merit-based incentive payment system (MIPS) performance threshold of 75 points for the 2026 performance period through the 2028 performance period, while also adopting six new MIPS Value Pathways (MVPs) and modifying performance categories under the Quality Payment Program. The new MVPs are for:
    • Diagnostic radiology
    • Interventional radiology
    • Neuropsychology
    • Pathology
    • Podiatry
    • Vascular surgery

The MHA will provide an updated impact analysis in the coming weeks. Members with questions should contact Vickie Kunz at the MHA.