CMS Is Asking How Home Health Wages Should Be Calculated. You Have Until August 31.
The CY 2027 proposed rule contains a request for information on building a home health specific wage index. Comments close 5 p.m. EDT on August 31, 2026. Here is exactly how to send one, and what to put in it.
Buried in the CY 2027 home health payment rule, past the case-mix recalibration and the LUPA thresholds, is one sentence worth your attention:
> "...includes a request for information (RFI) regarding the construction of a home health specific wage index."
A request for information is CMS saying, in public, that it does not have enough information and would like some. The comment period closes at 5 p.m. EDT on August 31, 2026.
Why the wage index matters to you
Medicare does not pay the same amount for the same visit everywhere. It adjusts by a wage index, which is meant to reflect what labour costs in your area. Higher index, higher payment.
The problem is where the number comes from. The home health wage index has long been built off hospital wage data. Hospitals and home health agencies do not pay the same people the same way, and they do not compete for staff in the same market. An index built on one and applied to the other will be wrong somewhere, and the places it is wrong are places where agencies are paid as though labour is cheaper than it is.
CMS is now asking whether it should build a home-health-specific one instead. That is a question about how much money flows into home care, and where.
The part nobody says out loud
The same rule proposes a net 2.4% increase — about $420 million — in Medicare payments to home health agencies for 2027, according to CMS's own fact sheet.
None of that money is required to reach you.
The rule sets what Medicare pays agencies. There is nothing in it obliging an agency to pass any share of an increase to the aides doing the visits. A separate Medicaid rule will eventually require a share of Medicaid payments to go to direct care worker compensation, but that is a different programme on a multi-year phase-in, and it is not this.
I am not saying agencies pocket it. Many of them are running thin, and a 2.4% increase against several years of cuts is not a windfall. I am saying the mechanism that decides your pay is not in this rule — and the one place this rule does touch it, the wage index, is exactly the thing CMS just said it wants input on.
Why your comment is worth more than you think
Every comment goes into a public docket. Under the rulemaking process, CMS has to consider significant comments and respond to them when it issues the final rule. It does not get to ignore the docket.
Read the comment file on a rule like this and it is agencies, trade associations, law firms, and consultancies. That is not a conspiracy — those are the people who read the Federal Register for a living. But it means CMS is trying to work out what home health labour actually costs, and is mostly hearing from people who do not do the work.
You know what an agency pays. You know what you are paid for travel between clients, or whether you are paid for it at all. You know what happened when the agency down the road raised its rate. CMS asked. Almost nobody who knows is going to answer.
How to send one
Refer to file code CMS-1844-P. Pick one of these — CMS asks you not to duplicate. Faxes are not accepted.
1. Online. Go to regulations.gov and search the file code CMS-1844-P. Open the proposed rule and use the "Comment" button. (I am deliberately not linking a docket URL: the pre-publication document lists the docket number as a placeholder, so any link I printed today could be wrong.)
2. Regular mail.
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1844-P
P.O. Box 8013
Baltimore, MD 21244-8013
3. Express or overnight mail.
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1844-P
Mail Stop C4-26-05
7500 Security Boulevard
Baltimore, MD 21244-1850
For mail, leave time. It has to arrive by the deadline, not be postmarked by it.
What to actually write
Do not copy a template. Identical comments read as one comment, and the whole reason yours is worth sending is that it contains something CMS cannot get anywhere else.
Four short paragraphs is plenty:
- Who you are. "I am a home health aide in [county, state]. I have worked in home care for [n] years." That is your standing. You do not need credentials beyond doing the job.
- What you are commenting on. Name the RFI on a home health specific wage index. One sentence.
- What you know. The concrete part. What you are paid per hour or per visit. Whether travel time between clients is paid. What the agency down the road pays. Whether your agency has been able to fill open shifts, and what that has done to your hours. Numbers and specifics beat adjectives.
- What you want. If you think the index should be built on home health wages rather than hospital wages, say that, and say why based on what you just described.
Then send it. It does not have to be long or polished — it has to be true and specific.
If you only do one thing
Put a reminder in your phone for August 25. That leaves you time to write something and, if you are mailing it, for it to arrive.
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A companion piece to [our breakdown of the CY 2027 rule for agency owners](/en/blog/cms-home-health-payment-rule-2027). Rule: CMS-1844-P, RIN 0938-AV80, published in the Federal Register on July 6, 2026. The deadline and submission addresses above are quoted from the rule's own DATES and ADDRESSES sections. Questions about the rule itself go to HomeHealthPolicy@cms.hhs.gov. This is general information, not legal advice.
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