If your agency got a CY 2027 Annual Payment Update (APU) non-compliance letter, you have until 11:59 pm on November 23, 2026 to ask CMS to reconsider it, and email is the only way in. CMS put the notices in agencies' iQIES My Reports folders on October 23, 2026, and the Medicare Administrative Contractors (MACs) are sending a copy by email or mail. If the finding stands, your 2027 Medicare payment update is 0.1 percent instead of 2.1 percent.
Updated November 12, 2026. Sources: CMS's HH QRP Spotlight and Announcements (opens in a new tab) (notice of October 23, 2026), its reconsideration page (opens in a new tab) (last modified November 6, 2026), 42 CFR 484.245 (opens in a new tab) as it reads today, and the CY 2027 HH PPS final rule, CMS-1844-F (opens in a new tab), published in the Federal Register on November 9, 2026.
Warning
Reconsideration only helps if you were compliant. Since the CY 2026 rule, 42 CFR 484.245(d)(4)(ii) says CMS "grants a timely request for reconsideration, and reverses an initial finding of non-compliance, only if CMS determines that the HHA was in full compliance with the HH QRP requirements for the applicable program year." An exception or extension CMS granted for an extraordinary circumstance counts as compliance. A good reason without an approved exception does not. CMS's reconsideration page still invites "evidence of the impact of extraordinary circumstances"; the regulation is what CMS decides by.
The Dates
| Date | What happens | Source |
|---|---|---|
| October 23, 2026 | CMS places CY 2027 APU non-compliance notices in iQIES My Reports folders; MACs send a letter by email or regular mail | CMS HH QRP Spotlight |
| November 23, 2026, 11:59 pm | Last moment to email a reconsideration request. The rule is 30 calendar days after the date on the letter | CMS HH QRP Spotlight; 42 CFR 484.245(d)(1)(ii) |
| Within 5 business days of your email | CMS acknowledges receipt. The automatic reply is not the acknowledgment | CMS reconsideration page |
| Mid-December 2026 (CMS estimate) | Decision, by letter from the MAC or CMS's reconsideration review contractor | CMS reconsideration page |
| January 1, 2027 | CY 2027 rates start: a 2.1% update, or 0.1% for agencies found non-compliant | CMS-1844-F |
CMS says plainly: "CMS will not accept any requests submitted after the thirty (30) day deadline."
What the Letter Is About
The CY 2027 APU looked at two sets of data, each on its own clock. The final rule's Tables 20 and 21 give the periods:
- OASIS: assessments from July 1, 2025 through June 30, 2026. Under 42 CFR 484.245(b)(2)(ii)(A), an agency must meet a threshold "set at 90 percent of all required OASIS or successor instrument records." CMS measures it with its Quality Assessments Only (QAO) formula: quality assessments divided by quality plus non-quality assessments, times 100. A start of care with a matching discharge or transfer counts as quality; one with no matching end of care, outside the windows CMS allows, does not. CMS's reporting schedule (opens in a new tab) put the Annual QAO Performance Report in iQIES on September 18, 2026, counting assessments completed in that year and submitted by August 5, 2026.
- HHCAHPS: survey data from April 1, 2025 through March 31, 2026. An agency with fewer than 60 eligible unique HHCAHPS patients is exempt only if it submits that patient count to CMS each year (42 CFR 484.245(b)(1)(iii)(A)).
The letter states CMS's reason or reasons. Your request has to repeat them, so start there.
How to File the Request
- Find the letter and its date. It is in your iQIES My Reports folder; the MAC's copy comes by email or mail. The 30 days count from the date at the top of the letter.
- Pull the evidence before it disappears. CMS's reconsideration page lists what it accepts: proof of submission, email communications, iQIES data submission reports, proof of earlier waiver approvals (including disaster exceptions), a copy of the CCN activation letter, and other documentation supporting the request. CMS keeps the QAO performance reports in iQIES for 120 days. From September 18 that is about January 16, 2027, by our count. Download yours now.
- Write one email. Send it to HHAPUReconsiderations@cms.hhs.gov (opens in a new tab) with the subject line HHA QRP Reconsideration Request, [your CCN]. 42 CFR 484.245(d)(2) requires all of the following:
| Include | Notes |
|---|---|
| CCN | Also in the subject line |
| Business name | As enrolled |
| Business address | |
| CEO or CEO-designated contact | Name, title, phone, email and mailing address. The address must be a physical address, not a post office box |
| CMS's reason(s) for non-compliance | As stated in the letter |
| Your reason(s) for requesting reconsideration | With all supporting documentation |
- Remove every piece of patient information. CMS's page: "If any documents included in a reconsideration request contain PHI/PII, the entire request will be rejected." Redact before you attach.
- Keep it under 20 MB. CMS will not process a larger email.
- Watch for the acknowledgment. If none arrives within five business days, CMS says to check the size and resend before the deadline.
CMS's regulation adds that it does not consider a request unless every required item is there (42 CFR 484.245(d)(3)).
If a Disaster Hits During the 30 Days
The CY 2026 rule added a way to ask for more time to file. Under 42 CFR 484.245(d)(5), if your agency is hit by an extraordinary circumstance beyond its control during the reconsideration period (CMS's examples include a cyber-attack, hurricane, tornado or earthquake), you can ask for an extension to file. The request goes by email to the same address, no later than 30 calendar days from the date of the notice, with your CCN, business name and address, CEO or designee contact details, the reason, and evidence of the impact such as photographs or news articles. CMS answers by email.
This is not the same as an exception for the reporting year itself. That request had to go in within 90 days of the event that stopped you reporting (42 CFR 484.245(c)(2)).
What Happens After
- If CMS reverses the finding, you get the full 2027 update.
- If CMS upholds it, your 2027 payment update is 0.1 percent. The final rule's Tables B13 and B14 put the national standardized 30-day payment, with the 3 percent temporary adjustment, at $2,092.69 for agencies that submit quality data and $2,051.70 for those that do not. That is about $41 less on every 30-day period before case-mix and wage index adjustments. Per-visit rates for LUPA periods are lower too (Table 16).
- If you disagree with the decision, CMS points to an appeal to the Provider Reimbursement Review Board under 42 CFR part 405, subpart R. A Board hearing needs $10,000 or more in controversy (42 CFR 405.1835(a)(2)); CMS's page says disputes of at least $1,000 but less than $10,000 go to an intermediary hearing run by Federal Specialized Services, at intermediary@fssappeals.com (opens in a new tab). Follow the PRRB's instructions (opens in a new tab).
- CMS publishes the outcome. For CY 2026, CMS posted lists of compliant, non-compliant and excluded agencies on its reconsideration page, dated March 16, 2026.
Info
From January 1, 2027, CMS's decision comes through iQIES. The CY 2027 final rule rewrites 42 CFR 484.245(d)(4)(i) to read: "CMS notifies the HHA of its final decision regarding any reconsideration request through a CMS designated data submission system." Today the rule also allows mail or an email from the MAC. The same rule renames the "letter of noncompliance" a "notification of non-compliance." Make sure at least two people at your agency can open the iQIES My Reports folder.
Next Year's APU Is Already Being Measured
The CY 2027 final rule moves the OASIS APU onto a calendar year, with a six-month bridge:
- 2028 APU: OASIS from July 1 through December 31, 2026, and HHCAHPS from April 1 through December 31, 2026. That window is open now. Our OASIS submission deadline article covers the transition.
- 2029 APU: OASIS and HHCAHPS for all of calendar year 2027. It is also the first year CMS intends to count private-pay and other non-Medicare, non-Medicaid patients in the 90 percent. All-payer OASIS in 2027 explains who counts and from when.
If your letter came from a QAO rate under 90 percent, the fix for next year is in the office, not the inbox: a discharge or transfer OASIS for every patient who leaves, submitted on time. The OASIS Edit Code Lookup reads any iQIES edit ID back to CMS's rule, and the OASIS-E2 Submission Validator catches the fatal edits agencies hit most before a record goes up.
Know which recert is due next
Enter the start of care, and Logicly works out each 60-day cert period and the recertification window. The dashboard shows what is due.
Key Takeaways
- CMS posted CY 2027 APU non-compliance notices in iQIES on October 23, 2026. Requests are due by email by 11:59 pm, November 23, 2026.
- Send one email to HHAPUReconsiderations@cms.hhs.gov (opens in a new tab), subject "HHA QRP Reconsideration Request, [CCN]", under 20 MB, with no patient information.
- CMS reverses a finding only if you were in full compliance, including through an exception it granted.
- An upheld finding makes your 2027 update 0.1 percent instead of 2.1 percent.
- From 2027, CMS sends its reconsideration decisions through iQIES. Keep two people with access to the My Reports folder.
Frequently Asked Questions
When is the OASIS APU reconsideration deadline in 2026?
11:59 pm on November 23, 2026. CMS placed the CY 2027 annual payment update non-compliance notices in iQIES on October 23, 2026, and says requests must reach it by email no later than 11:59 pm, November 23, 2026. The regulation counts 30 calendar days from the date on the letter, and CMS will not accept a request after that.
How do I send an HH QRP reconsideration request?
By email only, to HHAPUReconsiderations@cms.hhs.gov (opens in a new tab), with the subject line HHA QRP Reconsideration Request followed by your CCN. Include your CCN, business name and address, your CEO's or a designee's contact details with a physical mailing address, the reasons for non-compliance as stated in CMS's letter, and your reasons with all supporting documentation. Keep the email under 20 MB and remove all patient information.
Will CMS reverse a non-compliance finding if we had a good reason?
Only if you were in fact compliant. Under 42 CFR 484.245(d)(4)(ii), CMS reverses a finding only if it determines the agency was in full compliance with the HH QRP requirements for the program year. An exception or extension CMS granted for an extraordinary circumstance counts as compliance. A reason without an approved exception does not.
What does an upheld non-compliance finding cost in 2027?
Two percentage points off the 2027 payment update. CMS's CY 2027 final rule sets the update at 2.1 percent for agencies that submit quality data and 0.1 percent for those that do not. The national standardized 30-day payment, with the temporary adjustment, is $2,092.69 for compliant agencies and $2,051.70 for non-compliant ones.
When will CMS decide on my reconsideration request?
CMS's estimated timeline is mid-December. It acknowledges each request by email within five business days, and the automatic reply is not that acknowledgment. The decision comes by letter from the Medicare Administrative Contractor or CMS's reconsideration review contractor.
Sources
- CMS, Home Health QRP Spotlight and Announcements (opens in a new tab): "Home Health Quality Reporting Program: Non-Compliance Notifications," October 23, 2026. Read November 7, 2026.
- CMS, Home Health Quality Reporting Reconsideration and Exception & Extension (opens in a new tab): the email format, required contents, evidence, 20 MB limit, PHI rule, timeline and appeal route. Page last modified November 6, 2026; read November 7, 2026.
- CMS, Home Health Quality Reporting Data Submission Deadlines (opens in a new tab): the QAO performance report schedule and the 120-day retention.
- 42 CFR 484.245 (opens in a new tab), Requirements under the HH QRP (eCFR, as amended at 90 FR 55619, December 2, 2025): paragraphs (b)(1)(iii)(A), (b)(2)(ii), (c) and (d).
- CY 2026 HH PPS final rule, CMS-1828-F, 90 FR 55342 (opens in a new tab) (December 2, 2025), section III.F: the full-compliance basis and the extension to file.
- CY 2027 HH PPS final rule, CMS-1844-F, FR Doc. 2026-22750 (opens in a new tab), on public inspection November 4, 2026, published November 9, 2026 at 91 FR 72022: the CY 2027 payment update, Tables B13, B14 and 16, Tables 20 and 21 (APU data periods) and the amendments to 42 CFR 484.245(d).
- 42 CFR 405.1835 (opens in a new tab) and 405.1811 (opens in a new tab): the amounts in controversy for a Board hearing and an intermediary hearing.