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The HHVBP September 4 recalculation window just closed. The next critical date is October 16.

Agencies that filed recalculation requests by September 4 will see adjustments reflected in their Preliminary Annual Performance Reports when CMS publishes them October 1 — the only remaining opportunity to contest the CY2026 APP before the Final APR locks in November.

The HHVBP Preview Annual Performance Report recalculation request window closed September 4. If your agency identified a calculation error in your Preview APR — a wrong episode denominator, a miscounted OASIS pair, an MSPB-PAC attribution discrepancy — and submitted a recalculation request before the deadline, the next step is October 1. If your agency didn't review the Preview APR and the deadline passed without action, you are now locked out of the first review stage.

What happens October 1: Preliminary APRs

On October 1, CMS publishes Preliminary Annual Performance Reports in iQIES for every enrolled HHA. These incorporate any approved adjustments from recalculation requests submitted before September 4. If your recalculation request was approved, the adjustment appears in your Preliminary APR. If it was denied, the denial rationale will be included.

Agencies that disagree with a recalculation decision — either because the adjustment was denied or because a new discrepancy appears in the Preliminary APR calculation — have until October 16 to submit a reconsideration request. This is the second and final opportunity to contest the Annual Payment Percentage before the Final APR publishes.

What happens in November: Final APRs lock the CY2027 payment adjustment

Final Annual Performance Reports publish in November. The Annual Payment Percentage in the Final APR is the number applied to every Medicare FFS home health claim with a through date in CY2027. No adjustment requests are accepted after finalization. The payment adjustment range is −5% to +5% applied to each 30-day period episode throughout the full year.

For context on what that range means: an agency billing $2 million in annual Medicare FFS home health has a $200,000 spread between the worst- and best-case HHVBP adjustment. The Final APR is not a reconciliation payment — it is a per-claim multiplier applied continuously.

The CY2027 proposed rule final rule also drops in November

The CY2027 Home Health PPS Final Rule (CMS-1844-P) typically publishes in late October or November — the same window as HHVBP Final APRs. The proposed rule (published July 6 and covered here in detail) proposed a 2.4% net aggregate increase, a continuing −3.0% PDGM recoupment, and 20 LUPA threshold changes across 432 HHRGs. The comment window closed August 31. The final rule will reflect CMS's response to those comments and is effective January 1, 2027. Agencies should plan to update LUPA targets, rate models, and enrollment-compliance reviews as soon as the final rule publishes — not on January 1.

What your agency should do before October 16

  1. Pull your Preliminary APR from iQIES on October 1 and compare it to your Preview APR. If you submitted a recalculation request, verify that the approved adjustment is reflected correctly. If the adjustment was denied, read the denial rationale before the October 16 reconsideration window opens.
  2. Review the Preliminary APR denominator figures against your internal episode records. The same cross-reference your agency ran in August — total qualifying Medicare FFS admissions for CY2025, matched-pair OASIS completion rate — should be run again against the Preliminary APR. An error that wasn't apparent in the Preview APR sometimes surfaces when the recalculation result applies.
  3. Submit a reconsideration request by October 16 if you disagree with a calculation decision. This is the final mechanism available before the November Final APR locks. The reconsideration request covers the same narrow scope as the recalculation request — calculation errors in CMS's processing, not documentation quality or outcomes. Document the specific discrepancy and submit with supporting data.
  4. Confirm your November monitoring schedule for both the Final APR and the CY2027 Final Rule. Both publish in November, and both carry January 1, 2027 operational implications. LUPA target updates, rate modeling, and the HHVBP APP all need to be in your Q4 planning calendar now.

What we built for this

Carelytic's Quality Metrics dashboard tracks OASIS completion rates — the matched admission and discharge pairs that determine OASIS measure denominators in the HHVBP calculation — by clinician and caseload throughout the year. A missing discharge assessment creates a gap in the denominator that surfaces in an APR, not on the day the assessment was missed. The dashboard surfaces those gaps during the care period so the agency can close them before the performance year closes. The LUPA Risk Dashboard will be updated with CY2027 PDGM thresholds when the final rule publishes in November — agencies reviewing the Final APR and the Final Rule on the same November timeline have both tools in one platform.

This post is editorial commentary on publicly reported industry news, not legal or compliance advice. For your agency's specific situation, consult counsel and your CMS regional office.

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