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Home health value-based purchasing quality data fraud concerns knowingly false information used to change an agency’s later Medicare payments. Under the expanded model, performance in 2026 determines adjustments to Medicare fee-for-service claims in 2028. If you work in quality review or reimbursement, you may know why the clinical record and the submitted data tell different stories.
In this form of home health fraud, false healthcare quality data reaches Medicare through an agency-wide payment adjustment. The OASIS assessment supplies information to both payment grouping and quality measurement. We follow that connection with the people who prepare, review and reconcile those records.
The Centers for Medicare & Medicaid Services’ expanded value-based purchasing model adjusts Medicare fee-for-service payments from minus 5% to plus 5%, based on an agency’s quality performance relative to its peers. It covers Medicare-certified home health agencies nationwide, including the District of Columbia and U.S. territories. The adjustment applies to claims with ending dates in the payment year.
The agency began the expanded model with a preparation year in 2022. The first full performance year was 2023, and the first payment year based on that performance was 2025. The same distinction matters now: payment adjustments in 2026 reflect performance in 2024. A quality employee reviewing this year’s assessments and a reimbursement employee reviewing this year’s payments are looking at different stages of the program.
The Centers for Medicare & Medicaid Services assigns agencies to larger-volume or smaller-volume nationwide cohorts using their unique beneficiary counts from the preceding calendar year. These groups put similarly sized agencies together for benchmarks, achievement thresholds and payment adjustments. An agency that inflates its performance data competes against honest peers using a false account of patient care.
The 2026 score combines OASIS assessments, Medicare claims and patient surveys, with different weights for the larger and smaller cohorts. The measures and reports summary gives these category weights:
| Data Used in the Score | Larger-Volume Cohort | Smaller-Volume Cohort |
|---|---|---|
| OASIS assessments | 40% | 50% |
| Medicare claims | 40% | 50% |
| HHCAHPS patient experience surveys | 20% | 0% |
The OASIS measures cover improvement in dyspnea, or shortness of breath, and management of oral medications, together with the Discharge Function Score. The measures added in 2026 cover bathing using M1830, upper-body dressing using M1810 and lower-body dressing using M1820. Claims measure hospitalization, community discharge and Medicare spending, while surveys measure patients’ overall rating of home health care and willingness to recommend the agency.
Under the model’s scoring method, CMS compares achievement against the cohort with improvement against the agency’s own baseline and takes the higher care-point result. Weighted measure results combine into the Total Performance Score. To understand a disputed result, we connect the particular measure to its source data, the agency’s cohort and the performance period it represents. The payment consequence can arrive long after the assessment has left the quality reviewer’s desk.
The Discharge Function Score measures the percentage of patients who meet or exceed their expected function at discharge. The Centers for Medicare & Medicaid Services’ measure overview explains the comparison through self-care and mobility activities. These include eating, oral hygiene, toileting hygiene, moving from bed to chair, standing, walking and, for applicable patients, wheelchair activities.
The expected score accounts for the patient’s functional status at the start or resumption of care, age and clinical characteristics. The discharge result is measured against that individualized expectation. The starting assessment therefore helps set the result the agency is expected to achieve.
That makes the original clinical observation important at both ends of care. If an insider describes a changed functional response, we want to understand what the patient could do at that assessment, what the submitted response said and how it entered the measure. The assessment date and the disputed activity give the concern a specific patient and episode to follow.
For this measure, the Centers for Medicare & Medicaid Services treats skipped items, dashed items and Activity Not Attempted codes as missing data. It uses statistical imputation to estimate the most likely value for a missing self-care or mobility response. That estimate draws on the patient’s start-of-care or resumption-of-care items and data from patients with similar characteristics.
A blank does not simply fall out of the calculation. We follow the missing responses as well as the completed ones: the starting responses help determine both the expected discharge result and the estimated values used for missing items. An employee who knows why an item was missing, or why a recorded response changed, can explain something the final agency percentage leaves out.
CMS’s quality reports in iQIES provide agency-level and patient-level information about the Discharge Function Score. Those reports show each patient’s observed result as well as the agency’s percentage.
Those fields connect a disputed assessment to a particular patient’s result and then to the agency’s measure. We look at the underlying responses alongside the reported result, including any estimated values. An agency average compresses many clinical accounts into a number. The insider can explain the account behind it.
The Annual Performance Report shows the agency’s performance data and the adjusted payment percentage that will apply to Medicare fee-for-service claims for the relevant payment year. Eligible agencies also receive four Interim Performance Reports each year, with preliminary versions available quarterly. The interim reports let an agency see its developing performance before the annual payment result. The August 2026 Preview Annual Performance Report concerns 2025 performance and 2027 payments.
A correction request and what came of it can be part of the history behind the final percentage. We examine which data and which version of the report reached the payment calculation.
The evidence connecting clinical records to payment extends from the original observation to the submitted assessment, the measure result, the performance report and the paid claim. The remittance shows what Medicare actually paid after adjustments. Quality staff may understand the disputed assessment while reimbursement staff can explain where the percentage reached the payment. Together their accounts connect decisions made in different parts of the business.
The Home Health Quality Reporting Program separately ties the annual payment update to submission of required quality data. Under CMS’s quality-reporting requirements, failure to submit the required data reduces the home health market-basket percentage increase by two percentage points.
An insider’s account becomes concrete when it connects a clinical discrepancy to the submitted version and the calculation that used it. Who changed the response, who approved it and what happened when someone questioned it can explain the business decision behind the number. We put that account beside the measure and payment records.
We want to know what the agency knew about the difference. If an agency improves its payment by falsifying the score, taxpayers pay for better care that exists only in the data. We follow the changed assessment through the calculation to the government money. Better care on paper.
A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. If you are considering reporting home health fraud, your knowledge of the assessment, review or reimbursement work gives us a concrete place to start.
If you know which assessment changed or why a performance report carried the wrong data, talk with our whistleblower experts about the payment behind that score. We work beside you to build your strongest home health whistleblower case and bring in home health fraud whistleblower lawyers who understand quality measurement and Medicare reimbursement. We stay with you from the first conversation through the case, keeping your knowledge of the agency’s decisions at the center of the work.