The LTPAC Health IT Collaborative submitted comments to CMS on the proposed CY 2027 Home Health Prospective Payment System rule, urging the agency to ensure that home health is fully included in the nation’s interoperability and digital quality reporting strategy.

Home health agencies are essential partners in care transitions, chronic disease management, aging in place, and person-centered care. Yet they too often remain downstream from health IT policies and infrastructure designed primarily for hospitals and physician practices.

The Collaborative’s recommendations focus on five priorities:

• Recognize home health as a core participant in cross-setting interoperability policy.
• Align future home health data and reporting requirements with standards such as the Data Element Library, USCDI, and applicable PACIO Project FHIR implementation guides.
• Ensure future FHIR-based reporting pathways enable bidirectional exchange and fit into clinical workflows, not simply one-way reporting to CMS.
• Provide realistic implementation timelines, testing environments, phased milestones, and direct technical assistance for providers and vendors.
• Include home health agencies and their technology partners in TEFCA-related exchange efforts, interoperability testing, and national health IT innovation initiatives.

Modernization should not create disconnected reporting requirements or unrealistic compliance expectations for small, rural, and under-resourced agencies. Instead, federal policy should enable home health information to support coordinated, longitudinal care across hospitals, post-acute providers, hospice, community-based services, patients, and caregivers.

The Collaborative looks forward to continued engagement with CMS and ONC to help ensure that interoperable, person-centered health IT reaches the full LTPAC continuum, including care delivered at home.

Read the full comment letter below: