5 Challenges of PDGM and Their Ripple Effect on Accurate Operations, Staff, and Survival

Since its implementation, the Patient-Driven Groupings Model (PDGM) has represented the most significant overhaul of the home health payment system in over two decades. Moving away from a therapy-volume-based system to one driven by clinical characteristics, PDGM was designed to align payments more closely with patient needs.

However, in 2026, the industry is still grappling with the "ripple effects" of this model, which have fundamentally altered how agencies operate, staff, and survive.

1. The 30-Day Revolution: Cash Flow and Admin Strain

One of the most jarring shifts under PDGM was the transition from a 60-day billing cycle to a 30-day payment period. While the "episode of care" remains 60 days, the payment is split into two halves.

• Administrative Burden: This change effectively doubled the billing and documentation workload for office staff. Agencies now must process twice as many final claims and Requests for Anticipated Payment (RAPs) for the same period of care.

• Cash Flow Volatility: For smaller agencies with limited reserves, any delay in the 30-day billing cycle can lead to immediate liquidity crises, making it difficult to meet payroll or cover field expenses like fuel.



2. The Coding "Death Trap": Clinical Groupings

Under PDGM, every patient is assigned to one of 12 clinical groupings based on their primary diagnosis. If the diagnosis code is too vague (known as a "Questionable Engagement" or "Unacceptable" code), the claim is rejected instantly.

• The ICD-10 Specialist: This has forced agencies to hire highly specialized (and expensive) coders. A single-digit error in an ICD-10 code can mean the difference between a profitable case and a financial loss.

• Comorbidity Adjustments: PDGM allows for higher payments if a patient has secondary conditions (comorbidities). However, capturing this data requires exhaustive clinical documentation, adding to the burnout of field nurses who are already stretched thin.

3. The LUPA Risk: The "All-or-Nothing" Threshold

Under the old system, a Low Utilization Payment Adjustment (LUPA) was triggered if a patient received four or fewer visits. Under PDGM, the LUPA threshold is variable, ranging from 2 to 6 visits depending on the patient's specific grouping.

• Revenue Cliff: If an agency falls one visit short of the threshold—perhaps because a patient refused a visit or went to the hospital—the agency loses thousands of dollars, receiving only a low per-visit rate instead of the full 30-day payment.

• Clinical Integrity vs. Financial Survival: This has created an operational tension where managers must strictly monitor visit counts to ensure they don't hit a LUPA, leading to concerns about over-visiting or under-visiting based on math rather than medicine.

PDGM's Impact on Agency Operations (2026)

Primary Driver:

Old System (Pre-PDGM)- Therapy Volume (PT/OT/ST)

Current PDGM Reality- Clinical Diagnosis & Comorbidities

Billing Cycle:

Old System (Pre-PDGM)- 60 Days

Current PDGM Reality- 30 Days

Therapy Utilization:

Old System (Pre-PDGM)- High (Incentivized)

Current PDGM Reality- Moderate (Now an overhead cost)

LUPA Threshold:

Old System (Pre-PDGM)- Fixed at 4 visits

Current PDGM Reality- Variable (2–6 visits)

4. The Decline of Therapy-Heavy Care

Perhaps the most controversial result of PDGM is its impact on physical, occupational, and speech therapy. Since therapy volume no longer triggers higher payments, many agencies have reduced their therapy staffing or shifted toward a "nursing-first" model.

• Impact on Rehabilitation: Patients recovering from joint replacements or strokes may find it harder to get intensive daily therapy in the home, as agencies must now balance the high cost of therapists against a fixed payment rate.

5. Behavioral Adjustments: The "Invisible" Cut

To maintain budget neutrality, CMS implemented "behavioral adjustments, “essentially preemptive cuts based on the assumption that agencies would change their coding habits to maximize revenue.

In 2026, these permanent rate cuts continue to tighten margins. This leaves agencies with little room for error. For many providers, PDGM’s complexity is not just mathematical; it is the ongoing challenge of staying efficient enough to operate on shrinking reimbursement.

Final Thought: PDGM has successfully shifted the focus to clinical complexity, but it has also introduced a level of financial risk that rewards data-heavy, large-scale operations while making it increasingly difficult for smaller, community-based providers to stay afloat.

If you are struggling with sufficient reimbursement to stay viable, Kenyon HomeCare Consulting senior associates can provide an organizational assessment. The report, with the recommendations, will assist you in making the necessary adjustments. Additionally, our ICD-10 coding staff can provide 5 free recodes of your cases. This is accomplished with a review of the DC summary from the hospital, then a review of the OASIS scoring and the subsequent ICD-10 coding. All of the coders in our coding division are certified in both OASIS and ICD-10 coding.If you need assistance, call Kenyon HomeCare Consulting at 206-721-5091 or email gkenyon@kenyonhcc.com. We are here to help.