The Coalition to Transform Advanced Care (C-TAC) is encouraged by CMS’s proposed clarification in the CY2027 Home Health Proposed Rule. The clarification recognizes that community-based palliative care can be provided through the Medicare home health benefit when beneficiaries meet existing home health eligibility requirements. We welcome the opportunity to provide comments on this proposal, which has the potential to remove longstanding state and other barriers and improve access to high-quality, person-centered, interdisciplinary care for people living with serious illness and their caregivers.
Importantly, CMS is not proposing a new standalone palliative care benefit. Rather, the agency clarifies that palliative care services may already be covered under the existing Medicare home health benefit when a beneficiary requires reasonable and necessary skilled services. The proposal reinforces that eligibility should be based on an individual’s clinical needs, goals of care, and accepted standards of practice and not on whether a patient is terminally ill, has the potential for restoration, or has chosen to forgo life-prolonging treatment. This is an important recognition that palliative care is appropriate at any stage of a serious illness alongside curative and disease-directed treatment.
The proposal also acknowledges that high-quality palliative care is inherently interdisciplinary. CMS describes how the full range of Medicare home health professionals, which includes skilled nursing, medical social services, physical therapy, occupational therapy, and speech-language pathology, can work together to address symptom management, advance care planning, psychosocial support, care coordination, communication, functional goals, and quality of life. By recognizing that much of the interdisciplinary team already exists within the home health benefit, CMS is affirming that palliative care extends well beyond hospice and can be integrated earlier in the course of serious illness.
For many years, inconsistent interpretation of home health agency authority across states has created unnecessary barriers to delivering community-based palliative care. Home health agencies are already essential partners in expanding access to serious illness care, particularly in pediatric palliative care and in partnerships with health systems delivering home-based supportive care. In several states, including Washington and Utah, home health agencies already provide a significant share of community-based palliative care services, demonstrating both the feasibility of this approach and its potential to expand capacity for patients and families.
C-TAC views this proposal as an important opportunity to establish a clearer and more consistent pathway for delivering community-based palliative care through the Medicare home health benefit for appropriate patients. It does not suggest that all home health patients require palliative care nor that someone need be homebound to receive those services beyond the Home Health benefit. As part of the public comment process, we look forward to working with CMS to strengthen this policy through clear sub-regulatory guidance, practical examples of qualifying skilled palliative care services, expectations for interdisciplinary care planning and coordination, and documentation guidance that promotes consistent implementation by providers, Medicare Advantage plans, contractors, and survey agencies.
This proposal reflects an important evolution in Medicare policy and moves us closer to ensuring that every person living with a serious illness has access to high-quality, person-centered palliative care in the home. Meaningful policy change takes time, and this proposal is an encouraging signal that years of collaboration and advocacy are making a difference. As C-TAC marks its 15th anniversary, we are encouraged to see our longstanding work —and the vision outlined in our Core Principles for Care Models for Those with Serious Illness—reflected in the federal policy conversation.
