Marland & Co.Growth  ·  Management  ·  Capital

Building on a Rate You Don't Set

Marland & Co.4 min read

Most of your revenue is a number chosen by people you will never meet, and they can move it with a rule published in autumn that takes effect in January.

That is the part of this business no amount of operational excellence fixes. You can run the cleanest agency in your state and still open the Federal Register to find your base rate cut.

The number moves, and rarely up

Look at what just happened. In the summer of 2025, CMS proposed cutting aggregate home health payments by 6.4 percent for 2026. Owners spent months building budgets against that figure, some of them weighing whether to keep a branch open. Then in November the agency finalized the cut at 1.3 percent, roughly $220 million out of the system rather than the far larger number on the table in June, as Home Health Care News and others reported. Relief, technically. Also a demonstration. The distance between the proposed number and the final number was several points of your margin, and you had no vote in either.

Underneath the headline the mechanics keep grinding. The 2026 rule carries a permanent downward adjustment of about 1 percent and a temporary reduction of 3 percent that CMS itself described as a way to soften a cut that would otherwise threaten access. When the regulator writes that its own reduction is designed to avoid destabilizing providers, take the hint about the direction of travel. This is not the first year of it and it will not be the last.

The cap is a rate too

Hospice operators get a friendlier headline and a hidden trapdoor. CMS raised the hospice payment rate 2.6 percent for fiscal 2026 and lifted the aggregate cap to 35,361.44 dollars per beneficiary. That cap is not trivia. If your total Medicare payments exceed the cap times your patient count, you repay the difference. A hospice can post a strong year on paper and owe money back because its average length of stay ran long. That is a rate working backward, and it lands as a liability after you have already spent the cash on care.

Managed care sets a second rate

Even the CMS rate is only half the story now. Medicare Advantage enrollment reached about 55 percent of eligible beneficiaries in early 2025, and those plans do not pay the published rate. They pay what your contract says, which is usually less than fee-for-service and often slower. MedPAC has studied whether Medicare Advantage growth is crushing home health margins and found the aggregate effect small and statistically insignificant, but the same analysis noted smaller agencies take the larger hit. If you are a $5 million agency, the industry average is cold comfort. You feel the specific contracts you signed.

So you are not managing one rate. You are managing a federal rate that moves by rule, a hospice cap that claws back after the fact, and a stack of managed-care agreements each carrying its own number.

Plan for the rule, not the press release

Build your budget against the proposed cut, not the final one. When CMS floats 6.4 percent, model the agency at 6.4 percent and find out now whether it survives. If the final rule comes in gentler, you have a cushion. Plan for the gentle number and get the hard one, and you are cutting staff in January.

Read your contracts as if the rate can drop, because it can. Know which managed-care plans pay you below cost and what it would take to renegotiate or walk. A patient you serve at a loss is not volume. It is a subsidy you are paying to a health plan.

If you run hospice, watch your cap position all year, not at settlement. The cap is knowable in advance. Track average length of stay against it every month and a repayment demand will never surprise you.

You cannot control the rate. You can refuse to be caught flat when it changes. Owners get hurt when they treat this year's number as permanent. It never was.

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