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CMS’s proposed 2027 Medicare home health payment rule would clarify that covered skilled home health services may be palliative in nature. The proposal keeps current eligibility requirements and does not change the bundled payment structure that providers say can limit broader interdisciplinary care.
CMS has proposed clarifying that Medicare home health coverage can include skilled services provided for palliative purposes. The proposal is part of the agency’s calendar year 2027 home health payment rule. It would not change who qualifies for the benefit, and providers say broader interdisciplinary care may remain difficult to fund under current payments.
The proposal addresses how existing home health coverage requirements apply when care is palliative. Alliance for Care at Home vice president Katie Wehri told Palliative Care News that CMS is reviewing requirements for homebound status, skilled services and coverage, and clarifying that covered skilled services may be palliative in nature. The proposal does not establish a separate eligibility pathway.
Patients would still need to be homebound, require part-time or intermittent skilled services, have an in-person appointment with a doctor or other health professional confirming the need for home health care, and receive services from a Medicare-approved agency. CMS said in a fact sheet that it plans to issue sub-regulatory guidance with examples of skilled palliative care.
Providers cited potential benefits and limits. Wehri said examples in the guidance could help agencies feel more comfortable accepting patients whose needs are eligible but not clearly identified. LeadingAge’s Katy Barnett said agencies may form more relationships with oncologists and use physical or occupational therapy to help people manage conditions and function safely at home. She also said bundled payments can leave little money for social, spiritual or aide visits after nursing costs are covered.
How Coverage Could Reach More Patients
The clarification could make it easier for home health agencies to recognize and bill for skilled care whose goal is symptom management or support with a serious condition, rather than recovery alone. Wehri linked the proposal to the 2013 Jimmo Settlement, which clarified that Medicare coverage is based on the services a patient needs and is not limited to cases where improvement is expected. CMS’s proposal would apply that principle to the description of covered home health services.
For patients, the practical effect would depend on whether agencies can provide and coordinate the services they need. Barnett said the payment bundle often prioritizes nursing tasks, such as medication management and wound care, leaving limited funds for other disciplines. Wehri said a comprehensive interdisciplinary palliative plan is cost-prohibitive for many agencies under the current payment structure. The proposal may clarify coverage, but it does not itself resolve that funding constraint.
Existing Home Health Rules Remain
Medicare’s home health benefit already covers eligible patients who need intermittent skilled care at home. The proposed rule would clarify that such care can be palliative in nature while retaining the existing requirements for homebound status, skilled need, professional confirmation and use of a Medicare-approved agency.
Palliative care and hospice are distinct benefits. The report notes that home health agencies can face difficulty providing palliative services as broad as those available through the hospice benefit. Wehri said agencies that advertise comprehensive palliative care may deliver it through an affiliated Medicare Part B physician visiting service. The proposed clarification concerns services covered under home health; it does not establish that home health agencies will receive funding for a full hospice-style interdisciplinary team.
“The inclusion of palliative care as a bona fide reason for home health services was one of the standout positives in the rule for me.”
— Beau Sorensen, chief operating officer of First Choice Home Health & Hospice
Payment Limits and Guidance Details
The proposed rule does not specify the full set of examples CMS will include in its planned guidance or how reviewers will apply the clarification in individual cases. It is also unclear how many agencies will add or expand palliative services after the guidance is issued.
The proposal does not change the bundled payment structure described by providers. How agencies will pay for social, spiritual and aide services alongside skilled nursing remains an open question, as does how consistently patients will be able to access a broader interdisciplinary plan through home health.
CMS Guidance and Rulemaking
CMS plans to provide sub-regulatory guidance with examples of skilled palliative care. The proposal is part of the calendar year 2027 home health payment rule; the supplied report does not state a final rule date or the schedule for issuing that guidance. The clarification’s final wording and implementation will depend on further CMS action.
Key Questions
What would CMS’s proposal change?
It would clarify that skilled services covered under the Medicare Home Health Benefit may be palliative in nature.
Would the proposal change who qualifies for home health?
No. Patients would still need to meet existing requirements, including homebound status, a need for part-time or intermittent skilled services, professional confirmation of need and care from a Medicare-approved agency.
Does the proposal create a new palliative care payment?
The source material describes a coverage clarification within the existing home health benefit. It does not describe a separate payment or a change to the bundled payment structure.
Why do providers say broader palliative care may remain difficult?
Providers say the bundled payment can leave limited funds for social, spiritual and aide visits after nursing care is paid for, making a comprehensive interdisciplinary plan difficult to support.
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