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What the Data Reveals: Medicare Home Health Disparities
Medicare funding for end-of-life home healthcare is essential for supporting homebound adults who need skilled care. A recent study found Medicare Advantage (MA) enrollees tend to receive fewer home health services and for a shorter duration compared to those in traditional Medicare (TM).[1] This is particularly true for racial and ethnic minority patients.
In this blog, we break down what this research means for Certificate of Need (CON) applications, and how RPC uses Medicare data to find underserved populations, even when MA data is limited.
A 2025 study, “Racial Disparities in End-of-Life Home Health Use in Medicare Advantage vs Traditional Medicare,” examined whether Medicare Advantage plans have greater racial and ethnic disparities than traditional Medicare in home health utilization during the last year of life.[1] The study found that Medicare Advantage enrollees across all racial and ethnic groups had fewer opportunities to access home health services than those on traditional Medicare, with the most pronounced differences seen for Hispanic and Asian Pacific Islander enrollees.[1]
Medicare’s Standard Analytical Files (SAFs) provide valuable insight into home health utilization, but only for traditional Medicare enrollees. The SAFs do not have claims data for Medicare Advantage enrollees. When using the SAFs to analyze trends, it is important to exercise caution when drawing general conclusions because Medicare Advantage enrollees’ may be different. This is particularly true in states with a larger number and percentage of Medicare Advantage enrollees. State Medicare Advantage enrollment rates vary widely — from a low of just 2% of enrollees in Alaska to a high of 62% in Michigan.[2]
RPC’s Data-Driven Approach
RPC uses Medicare home health SAFs to identify underserved demographic groups and clinical services for Certificate of Need (CON) projects in many states. In recent home health projects in Tennessee and Washington, DC, RPC used SAF data to advocate for a higher home health-use rate than the state average, and to highlight certain patients with behavioral health diagnoses that were underserved. Whenever possible, RPC incorporates information on Medicare Advantage enrollees from published articles or state publications and data. This lets us draw conclusions for the entire Medicare population.
RPC uses Medicare data in our development of CON applications and oppositions for inpatient hospitals, outpatient surgery projects, home health, and hospice. We provide CON services to healthcare providers in many states. Our experience spans 30 years and about as many states. We work to anticipate the arguments that opponents and competing applicants will make in the project design and the supporting documentation.
[1] Jones, Tessa, Carmen Vargas-Torres, David J. Meyers, R. Sean Morrison, and Claire K. Ankuda. 2025. Racial Disparities in End-of-Life Home Health Use in Medicare Advantage vs Traditional Medicare. JAMA. 2025 ;333(10) :902-904. Doi :10.1001/jama.2024.27493
[2] https://www.cms.gov/data-research/statistics-trends-and-reports/medicare-advantagepart-d-contract-and-enrollment-data/monthly-enrollment-state/monthly-enrollment-state-2025-05
If you have questions or a project you would like to discuss, please contact Darcy Schaeffer, MLS, at 512.371.8011, dscheaffer@rpcconsulting.com