Home Health QRP Reconsideration: What to Do if CMS Sent a Non-Compliance Notice

CMS has started telling some home health agencies that they missed the bar for quality reporting, and the clock to respond is already running. On Oct. 23, CMS placed Home Health Quality Reporting Program (HH QRP) non-compliance notices for the calendar year 2027 annual payment update into agencies' My Reports folders in iQIES, and Medicare Administrative Contractors are mailing or emailing letters as well. Agencies that think the finding is wrong have until 11:59 p.m. on Nov. 23, 2026 to file a home health QRP reconsideration request. Missing the bar costs real money: an agency that falls short has its annual payment update cut by 2 percentage points.

What triggers a home health QRP reconsideration

The core test is simple to state. Each submission year runs July 1 through June 30, and an agency has to submit at least 90 percent of its required OASIS records through iQIES. CMS measures this with what it calls the Quality Assessments Only formula, which counts the assessments that can form a complete quality episode against the ones that cannot. A start of care without a matching discharge or transfer, for example, drags the number down. Agencies can only file for reconsideration if they received a non-compliance letter, and CMS reverses the finding only when the agency shows it was in full compliance for that program year.

What a request has to include

The process is email only, sent to HHAPUreconsiderations@cms.hhs.gov with the subject line "HHA QRP Reconsideration Request" followed by the agency's CCN. The request needs the agency's business name and physical address, contact details for the CEO or a designee, the reasons for non-compliance listed in the letter, and documentation that supports the agency's case. CMS points to iQIES data submission reports, proof of submission, email records, prior waiver approvals and the CCN activation letter as typical evidence. Two rules sink requests quickly. Files over 20 MB are not processed, and any protected health information anywhere in the packet gets the whole request rejected, so redaction has to happen before anything is sent.

The bigger shift coming in January

Even agencies that did not get a letter this year should look at their numbers. Today only Medicare and Medicaid OASIS data count toward the payment update calculation. For patients with a start of care on or after Jan. 1, 2027, CMS intends to include all non-Medicare and non-Medicaid patients too, and the 90 percent threshold applies regardless of payer. That means private-pay and commercial admissions that were easy to overlook will soon affect the same payment update. A quick monthly check of iQIES submission reports against the agency's own census is a cheap way to catch missing assessments while they can still be fixed.

Quality reporting is one of those areas where the work is mostly about records lining up: who was admitted, which visits happened, and which assessments closed each episode. That is the kind of visibility we think about every day at CareSync®. We are also quietly building something for home health professionals who want to compare notes on changes like this one, and we hope to share more soon. If your agency received a notice this year, the CMS reconsideration page has the full instructions, and Nov. 23 is the date to plan around.

Sources: CMS Home Health QRP Spotlight and Announcements (Oct. 23, 2026); CMS Home Health Quality Reporting Reconsideration and Exception & Extension; CMS Home Health Quality Reporting Requirements.