Ready, Fire, Aim: The CY 2027 Home Health Proposed Rule’s Shoot-First Approach to Provider Enrollment

CMS’s CY 2027 Home Health Proposed Rule tucks a sweeping set of Medicare provider enrollment changes inside what is nominally a routine payment rule, expanding the grounds on which CMS can deny or revoke a provider’s enrollment. In this episode, Husch Blackwell’s Bryan Nowicki and Andrew Brenton unpack several of the rule’s most consequential proposals, including new denial and revocation grounds and retroactive revocation effective dates. They also discuss why home health agencies and hospices should be paying close attention as the rule moves toward finalization.