Medicare’s 2027 home health rule extends retroactive revocation to grounds that previously operated only going forward. An agency collecting $1M/month could have six months of revenue in the exposure analysis.
The 2.4% aggregate payment increase and the 3% temporary reduction aren’t contradictory. The prior year already carried that temporary factor. The rate math is layered, and multiplying last year’s revenue by the update figure produces a misleading budget.
Ownership changes within 36 months of enrollment or the last majority ownership change can require re-enrollment. The new rule adds denial and revocation authority when that process isn’t followed. A deal described as a recapitalization isn’t automatically exempt.
The enrollment risk, ownership diligence requirements, geographic concentration authority, home infusion expansion, and palliative care clarification each create specific operating problems with specific people responsible for solving them. That’s the frame that matters.
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