Navigating the 2026 Final Rule: Strategies That Actually Work

The 2026 Home Health Final Rule is late—but the impact is already here. In this episode, Melissa Brown (COO) sits down with Devin Kassi, Gravity’s VP of Home Health Operations, to break down what agencies should be doing right now to prepare for payment cuts, VBP changes, and rising operational demands.

Together they unpack:

• What a 3–6% payment reduction really means for agency sustainability
• Why your EMR might be costing you more than it’s saving you
• How AI-driven clean claims, documentation support, and automated intake can reduce labor needs and boost margins
• The organizational restructuring every agency should be evaluating before 2026
• How to prepare for the proposed Value-Based Purchasing changes—especially new OASIS measures for bathing and dressing
• Why recurring training, ongoing Oasis auditing, and external quality support are now essential
• Practical, actionable steps to future-proof your operations before the Final Rule arrives

This is Part 1 of a two-part conversation designed to give home health leaders a roadmap for navigating reimbursement cuts without compromising care or burning out their teams.

Because in today’s environment, survival isn't about what you know—it's about how fast you can adapt.

Transcript

Melissa Brown (Speaker 1):
Hello, everyone. Welcome to the Gravity Healthcare Hacks podcast. Excited today to have Devin Kassie, our Vice President of Home Health Operations, here with me to discuss all things about the final rule for home health. As you well know, as of the time of this recording here near the end of November, the final rule actually hasn't come out yet—it's a little bit later than it normally is—but we have a lot of information to go off of from the proposed rule.

So we just want to talk strategy with you today and give you some tools to think about as we move toward getting the final rule and navigating 2026 successfully. Thanks so much for being here with me today, Devin.

Devin Kassie (Speaker 2):
Yes, thank you, Melissa. I'm really excited to be here as well to dive into some really great information involving the proposed rule and how we're going to move into 2026 to ensure that home health agencies are going to thrive.

Melissa:
Yeah, absolutely. I think probably the number one thing on everybody's list is the payment reduction that's proposed. And I'm sure we'll have some sort of reduction in the final rule. What are your thoughts about that? As someone who operates home health agencies and oversees agencies on behalf of clients, what are you doing? Where's your headspace with all that?

Devin:
Yes—just like any other home health agency out there, we’re really taking a deep dive into how we're going to manage a 6.4% decrease going into 2026. This is huge. PDGM came out in 2020, so over five years ago, and we are still being penalized for behavioral adjustments CMS believes we’re going to make because of the payment model. It's disappointing, but it's something we have to adapt to.

Whether it's 2026 or 2027, this is the reality. Home health is still the future of care, so we need to adapt to ensure we can thrive. This will be a short period in time when this occurs.

Melissa:
Yeah, and it's interesting. In all the years I've been reading proposed and final rules, this trend repeats: Medicare proposes a big cut, advocacy happens, and then the final cut is about half of the proposed cut. So if they propose 6.4%, they probably always intended around 3%.

Let’s dive into specifics. Tell us a couple of strategies you’re using as you're overseeing agencies. How are you thinking about absorbing a 3–6% cut in an era when prices keep escalating?

Devin:
Absolutely. One of the number one factors is to ask yourself: When was the last time I really dove into the technology we use? Specifically your EHR system. Are you using it to its fullest capability? When did you last talk to your vendor about upgrades, add-ons, or new features?

There are technologies now using AI and automation to streamline intake, documentation, and billing. For example, some systems can automatically populate referrals, face-to-face documents, medications—no hand-keying. That's huge for accuracy and time savings.

There are systems where clinicians can dictate their visit notes, goals, and interventions directly into OASIS—cutting documentation time dramatically. Labor is the biggest cost in home health. If we can reduce time spent documenting, we improve efficiency, reduce burnout, and improve accuracy.

Exploring these technologies and asking for demos is key. You might even find your current system isn’t capable of taking you into the future.

Melissa:
Yeah. One of the little-known secrets is that you sometimes need to spend more on an EMR to make more money. A best-in-class EMR improves clinician efficiency, billing, accuracy, compliance—and can eliminate certain personnel needs altogether.

I’m working with a client right now on technology improvements. A really good human can get a 95% clean-claim rate on first pass. AI can hit 98–99%. That dramatically reduces the hours needed for billing follow-up.

However, people have to become comfortable trusting AI. And you have to look at the quality of the data you get. Dashboards can look flashy, but if they don’t produce actionable insights, they aren’t valuable. If a report just tells you you're not making money—well, you already know that. You need it to tell you why, and where to take action.

If the data doesn’t lead to action, the technology isn’t worth buying. What do you think, Devin?

Devin:
I completely agree. Every agency is different—size, referral types, structure—so you need to evaluate what’s best for your agency. Look at every factor and consult experts when needed. Technology must support your structure, not just look impressive on paper.

Melissa:
Yes. And even as a consulting firm, our productivity has gone up 50–75% because of AI. You need to ask how and where those gains can happen in your agency.

A clinical manager with 100+ patients can’t take on much more, but back-office positions absolutely can change. Intake and billing especially. With the right technology, one person can do the job of two. So instead of eliminating a great employee, think: How else can I use them?

Your competitors are doing this. So if you're a smaller agency, leveraging technology is the only way to compete.

What else from the proposed rule should providers be thinking about?

Devin:
Let’s discuss changes to Home Health Value-Based Purchasing. VBP is becoming a major component of reimbursement. For 2026, the proposed rule removes three HCAHPS measures:

• Care of patients
• Communication between providers and patients
• Specific care issues

They're replacing these with four measures—three new OASIS measures (bathing, dressing, etc.) and one claims-based measure: Medicare spending per beneficiary.

If your agency scored high on the removed HCAHPS measures but struggles with functional OASIS items, this could significantly impact reimbursement. So you need to know how you’re currently scoring and what adjustments are needed going into 2026.

Melissa:
Right. And bathing and dressing outcomes require actual clinical improvement, not just good process or communication. It’s much harder to manipulate, which is what CMS wants.

So agencies need accuracy in OASIS, therapist mentorship, and strong quality support. What strategies would you implement?

Devin:
First, review your quality processes—both for VBP and HCAHPS. Look at your baselines. Then consider whether you're reviewing OASIS manually or with technology. If you're scrolling through OASIS by hand, you’re missing errors.

Some tools flag mismatched responses or items that don’t make clinical sense—prompting follow-up before documentation is finalized.

Consider whether your quality review is in-house or outsourced. And evaluate the training of your quality reviewers. When was their last true expert-level training? Ongoing education is critical—not just once a year.

Melissa:
Yes. This is not a “set it and forget it” situation. Agencies need a recurring cycle of:

• Training
• Auditing
• Education
• More auditing
• And outside validation

Internal auditors can have conflicts of interest. Outside auditors provide unbiased validation—and they won’t get pulled into putting out internal fires.

And Devin, as usual, we’ve talked long enough that we’ll need to split this into two podcasts. So we’ll end Part 1 here.

Don’t forget to tune in next month for Part 2, where we’ll pick up right where we left off—talking about strategies for the 2026 final rule.

Thank you, everyone, for joining us. And remember: It’s not just what you know, but how you apply it that makes all the difference. See you next time.