Academy Responds to CMS 2026 HH PPS Proposed Rule

The Academy has submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) on the 2026 Home Health Prospective Payment System (HH PPS) Proposed Rule.

In its response, the Academy urged CMS to withdraw the orthotics and prosthetics (O&P) provisions of the proposed rule. These provisions would impose annual accreditation surveys and related requirements on O&P facilities—despite decades of safe, effective care under the established three-year accreditation cycle.

The Academy’s comments highlighted that:

• O&P care is fundamentally clinical and patient-specific and should not be regulated as commodity-based DME.
• Imposing annual surveys would create disproportionate financial and administrative burdens for providers, especially small and independent practices.
• Enforcement data show that O&P is not the source of widespread Medicare fraud; targeted, risk-based oversight would be more effective.
• Preserving flexibility in the prior authorization process is essential to protect patient access and provider stability.

Read the Academy’s full written response.