Key Takeaways:
The most encouraging news is that the PFS final rule fixes a policy error from last year to recalibrate SNF physician payments to be the same for both long-stay residents and short-stay patients. It also delayed certain changes to remote patient and therapeutic monitoring (RPM/RTM) policies that would have been challenging.
In the HH final rule, while many of the provisions were adopted as proposed, CMS did not finalize or substantially improved several enrollment denial or revocation triggers that AHCA/NCAL commented on.
More of AHCA/NCAL’s preliminary analysis below.
Physician Fee Schedule Final Rule
The PFS final rule, despite a modest statutory negative adjustment, fixes a policy error from last year to recalibrate SNF physician payments to be the same for both long-stay residents and short-stay patients. It also delayed certain problematic changes to remote patient and therapeutic monitoring (RPM/RTM) policies.
Specifically:
- PFS Payment Rates to Decrease Slightly: Providers able to participate in PFS incentive programs will have a 1.83% reduction in their PFS conversion factor in CY 2027, while providers not able to participate will have a 2.31% reduction in their PFS conversion factor.
- SNF Physician Payment Adjustment Equalizes Long and Short-Stay: CMS restored adequate physician payments for services furnished to SNF patients during a Part A stay. The CY 2027 final rule equalizes payments to the long-stay resident levels.
- Telehealth Policies: Telehealth flexibilities policies extend through December 31, 2027, while audio-only telehealth authority extends through January 1, 2028, and geographic and originating site restrictions remain waived through 2027. CMS also finalized new telehealth billing modifiers and added several new services to the Medicare Telehealth List, including speech-language pathology, advance care planning, and shared medical appointments.
- Physical Therapy, Occupational Therapy, or Speech-Language Pathology Policies: CMS finalized increases to the annual therapy threshold, including $2,540 for Physical Therapy + Speech-Language Pathology (SLP) combined and $2,540 for Occupational Therapy. Targeted medical review threshold remains $3,000 through CY 2027. Additionally, CMS finalized several changes to SLP coding, including that several new SLP codes be designated as Always Therapy services, and excluded the 15-minute add-on codes from MPPR. Finally, CMS finalized a new optional SLP Healthcare Common Procedure Coding System code GSLPP for the treatment of speech, language, voice, communication, and/or auditory processing disorders for pediatric patients.
- Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM): CMS finalized most of its proposed changes. However, multiple changes were adopted in full or in part, including preserving important RPM/RTM resources/flexibility and providing meaningful initiating-visit flexibility, including telehealth, use of visits addressing other needs, and protection for beneficiaries already receiving monitoring before January 1, 2027. The adopted RPM/RTM employment restriction remains a major concern. CMS delayed implementation until January 1, 2029.
- Medicare Shared Savings Program: CMS finalized most Medicare Shared Savings Program (MSSP) policies as proposed, strengthening financial incentives and reducing administrative burden to encourage greater provider participation in MSSP. CMS also addressed concerns about how the beneficiary assignment changes could affect long-stay nursing facility residents. CMS conducted additional analysis, retained the proposed policy effective in performance year 2028, and committed to monitoring its impact.
Home Health (HH) Prospective Payment System
CMS’s CY 2027 Home Health final rule, effective January 1, 2027, reflects several important updates on provider enrollment that impacts all provider types.
- CMS did not finalize its proposal to allow denial of one enrollment to trigger revocation of a provider’s other enrollments.
- CMS also withdrew proposed expansions of debt-based and payment-suspension denial authorities involving additional associated parties and business or financial relationships.
These decisions addressed AHCA/NCAL’s concerns that broad enforcement authorities could jeopardize otherwise compliant providers based on circumstances insufficiently connected to their operations.
CMS partially addressed other recommendations by removing beneficiary relationships from the expanded affiliation definition and clarifying that providers are not required to continuously investigate or monitor affiliations. It confirmed that the documentation provision applies only to records already covered by existing enrollment requirements and creates no new condition of payment.
It also codified corrective action plans for certain enrollment denials, established rebuttals of reactivation effective dates, and added a signage cost estimate. These changes provide useful protections and clarification, although CMS declined many requested safeguards concerning materiality, reasonable due diligence, correction opportunities, and implementation flexibility.
Next Steps
AHCA/NCAL will continue to advocate for solutions that support a sustainable and modern Medicare reimbursement system. We’ll also continue pursuing an LTC-focused accountable care pathway, attribution that reflects residents’ current care relationships, timely and reliable ACO assignment information, meaningful participation in shared savings, and appropriate relief from the three-day inpatient stay requirement. Finally, we’ll continue advocating that policymakers focus on proportionate enforcement while balancing requirements to protect beneficiary access and continuity of care.
Please contact AHCA/NCAL’s Associate Vice President of Therapy Advocacy Daniel Ciolek with questions about the PFS Final Rule and HH Provider Enrollment provisions or Vice President of Reimbursement Policy & Population Health Nisha Hammel with questions about MSSP.