Regulatory Updates

The April 2026 Checklist: 5 Changes Hitting Home Health Agencies at Once

Five major CMS changes are landing in April 2026. Here's what they are, how they connect, and a week-by-week action plan.

The April 2026 Checklist: 5 Changes Hitting Home Health Agencies at Once

Change #1: OASIS-E2 Goes Live on April 1

Every assessment with a completion date (M0090) on or after April 1, 2026 must use the OASIS-E2 data set. This is a hard cutover, not a grace period.

The changes themselves are manageable but require clinician awareness. The COVID-19 vaccination item (O0350) is removed from all time points. The Gender item (M0069) is replaced with Patient's Sex (A0810), aligning home health with other post-acute care settings like SNFs and IRFs. The Transportation item (A1250) is retired and replaced with A1255, matching language used across CMS data sets. And for Resumption of Care assessments, clinicians will now need to complete hearing, vision, and language items that previously only appeared at Start of Care.

None of these are conceptually difficult. The risk is not complexity. It is habit. Clinicians who have been completing OASIS-E for years will default to old patterns unless the changes are reinforced in the weeks leading up to April 1. This is where a quick huddle or microlearning touchpoint makes the difference between a clean transition and a month of rejected submissions.

Change #2: The Revised HHCAHPS Survey Begins

Starting with the April 2026 sample month, patients will be surveyed using the revised HHCAHPS questionnaire. CMS reduced the survey from 35 questions to 30 by removing 8 task-focused items and adding 3 new ones that measure how patients and families feel about their care.

The most significant addition asks patients: "How often did you feel that home health staff cared about you as a person?" Two other new questions assess whether families received adequate information and whether the care helped patients manage their own health.

I wrote a detailed breakdown of these changes and what they mean for your team last week. The short version: CMS is moving from measuring task completion to measuring trust and connection. Agencies that prepare their clinicians for this shift before the first surveys go out will have a meaningful scoring advantage.

Change #3: New HHVBP Functional Improvement Measures

The Home Health Value-Based Purchasing expanded model adds four new measures for the 2026 performance year. Three are OASIS-based functional improvement measures: Improvement in Bathing (M1830), Improvement in Upper Body Dressing (M1810), and Improvement in Lower Body Dressing (M1820). The fourth is the claims-based Medicare Spending Per Beneficiary Post-Acute Care (MSPB-PAC) measure.

These additions come alongside a rebalanced VBP scorecard. For larger-volume agencies, the weights now break down to 40% OASIS-based outcomes, 40% claims-based measures, and 20% HHCAHPS. The three largest individual measure weights (15% each) go to Discharge Function Score, Within-Stay Potentially Preventable Hospitalization (PPH), and Discharge to Community (DTC-PAC). MSPB-PAC enters at 10%.

The new functional improvement measures complement the existing Discharge Function Score by capturing progress during the episode, not just the endpoint. This means documentation of functional status at SOC needs to accurately reflect the patient's baseline. If clinicians over-score bathing or dressing ability at admission, the improvement margin shrinks and the measure suffers. Accurate, honest SOC documentation is now directly tied to VBP performance on five separate measures, not just one.

Change #4: Updated Quality Measure Manual (v3.1) and Risk Adjustment Specs

On March 4, 2026, CMS released the updated Home Health Quality Reporting Program Quality Measure User's Manual (version 3.1) along with the 2026 Risk Adjustment Technical Specifications. These apply to quality episodes with SOC/ROC completion dates starting January 1, 2026.

The updated risk adjustment models are built on CY2024 episode data calculated in CY2025. This means the benchmarks your agency is being compared against have shifted. If your quality scores looked strong under the old models, they may look different now, not because your care changed but because the comparison framework did.

Quality directors should download the v3.1 Change Table from the CMS Home Health Quality Measures page and review it against their current QA processes. Pay particular attention to any changes in how quality episodes are defined and how risk factors are weighted. The agencies that catch discrepancies early will have time to adjust documentation patterns before the data hardens into public reporting.

Change #5: Legacy HHCAHPS Composites Removed from VBP Scoring

The three HHCAHPS composite measures that agencies have tracked for years (Care of Patients, Communications Between Providers and Patients, and Specific Care Issues) are being removed from VBP scoring in 2026. CMS cannot score composites built on the revised survey questions against baselines that do not exist yet.

For the 2026 performance year, only Overall Rating of Care and Willingness to Recommend will carry the HHCAHPS weight in your VBP Total Performance Score. This is a transitional arrangement. When the new composites come online (expected 2027 or 2028), CMS will establish fresh baselines using data collected starting April 2026.

This creates a strategic window. The scores your team earns on the new HHCAHPS questions in 2026 will contribute to the baselines that determine future achievement thresholds. Agencies that perform well immediately will be positioned above the curve when those baselines lock. Agencies that treat 2026 as a throwaway year will find themselves chasing higher benchmarks set by competitors who started earlier.

How These 5 Changes Connect

These changes are not five separate projects. They are one interconnected system.

OASIS-E2 feeds the new VBP functional improvement measures. If your clinicians are not accurately documenting bathing and dressing status on the E2 data set, your VBP scores on those three new measures will suffer. The revised HHCAHPS survey feeds the remaining VBP patient experience component. The updated QM manual changes how all of these scores get calculated and benchmarked.

The through-line is clear: CMS is simultaneously raising the bar on functional outcomes, patient experience, and data accuracy. Each change reinforces the others. An agency that prepares for OASIS-E2 in isolation but ignores the HHCAHPS shift will only solve half the problem.

Your 30-Day Action Plan

Here is how I would prioritize if I were running quality at an agency right now.

This Week (March 23-28): Confirm your EMR vendor has deployed the OASIS-E2 update. Review the item-level changes (A0810, A1255, ROC additions) with your clinical leads. Send a 2-minute microlearning summary to all field clinicians covering what changed and what to look for on their first April assessment.

Week of March 30: Run a mock assessment using the E2 data set with your most experienced clinician. Identify any workflow friction before it hits the full team. Begin introducing the three new HHCAHPS questions to clinicians through short daily huddle topics: one question per day, focused on what behavior drives the answer.

Week of April 6: Spot-check the first week of April OASIS submissions for E2 compliance. Flag any assessments still using old item numbers. Start the spaced repetition cycle on functional documentation accuracy for bathing (M1830) and dressing (M1810, M1820). Use brief case scenarios: "Patient can bathe with setup help only. How do you score M1830 at SOC?"

Week of April 13: Review your agency's position relative to the new QM v3.1 benchmarks. Compare your latest quality scores against the updated risk adjustment specs. Adjust documentation training if any measures show unexpected movement. Continue reinforcing HHCAHPS behaviors and functional scoring through weekly huddle topics.

Ongoing: Build a recurring cadence. One HHCAHPS behavior topic per week. One functional documentation scenario per week. Monthly QA review of OASIS-E2 submissions. This is not a one-month project. It is a new operating rhythm.

Key Takeaways

  • Five major CMS changes take effect in April 2026: OASIS-E2, revised HHCAHPS survey, new HHVBP measures, QM manual v3.1, and removal of legacy HHCAHPS composites from VBP.
  • These changes are interconnected. OASIS-E2 data feeds VBP functional measures. HHCAHPS scores feed VBP patient experience. The QM manual changes how both get benchmarked.
  • Accurate SOC documentation of bathing and dressing status is now directly tied to VBP performance on five measures, making functional assessment training a top priority.
  • The 2026 HHCAHPS scores will set the baselines for future VBP composites. Strong early performance creates a lasting competitive advantage.
  • One-time training will not sustain these changes. Use microeducation, spaced repetition, and weekly huddle reinforcement to build the behaviors into daily practice.

Frequently Asked Questions

When exactly does OASIS-E2 take effect?

OASIS-E2 is effective for all assessments with a completion date (M0090) on or after April 1, 2026. There is no grace period. Any assessment completed on or after that date must use the E2 data set, regardless of when the SOC or ROC occurred.

Will the new HHVBP measures affect my 2026 payment adjustment?

The new functional improvement measures (Bathing, Upper Body Dressing, Lower Body Dressing) and MSPB-PAC are part of the 2026 performance year scoring. However, VBP payment adjustments typically apply two years after the performance year, so these measures will influence your 2028 payment adjustment.

What should I do about the QM manual v3.1 changes?

Download the Change Table from the CMS Home Health Quality Measures page and review it with your quality team. Compare your current quality scores against the updated benchmarks. The new risk adjustment models are based on CY2024 data, which means your relative standing may have shifted even if your care delivery has not changed.

How do I prepare clinicians for all five changes at once?

Do not try to cover everything in a single training session. Prioritize by urgency: OASIS-E2 first (hard April 1 deadline), then HHCAHPS behaviors (surveys begin in April), then functional documentation accuracy (ongoing). Use microeducation to deliver one focused topic per day or week, reinforced through team huddles and real case scenarios.

Are the old HHCAHPS composite measures gone permanently?

The three legacy composites (Care of Patients, Communications, Specific Care Issues) are removed from VBP scoring in 2026 because they cannot be scored against the revised survey. CMS will develop new composite measures based on the revised HHCAHPS data. Once sufficient baseline data has been collected (expected 2027 or 2028), new composites will be introduced into VBP scoring.

Author :
Dr. Monika Virk, MD
The April 2026 Checklist: 5 Changes Hitting Home Health Agencies at Once
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