LeadingAge Leads Coalition Warning Against Home Health Proposed Rule Changes

WASHINGTON—In a joint sign-on letter led by LeadingAge, a coalition of 19 partners representing hospitals, physician and clinician practices, post-acute and long-term care providers, home health and hospice agencies and suppliers warned the Centers for Medicare & Medicaid Services (CMS) that changes to Medicare provider enrollment provisions included in the proposed payment rule for home health risk penalizing legitimate providers and could result in limiting beneficiary access to care. 

The coalition said it fundamentally supports CMS’ responsibility to protect the Medicare Trust Fund and beneficiaries from fraud, waste and abuse. However, the letter said the proposed changes to Medicare provider enrollment policies expand enforcement tools without providing the objective standards, clear definitions and procedural safeguards necessary to ensure that legitimate providers are not mistakenly swept into enforcement actions. 

The letter continued to say that, as drafted, these provisions could expose providers to severe consequences based on clerical errors, documentation discrepancies, circumstances outside their control or loosely defined associations with third parties, rather than intentional fraud or abuse. 

Urging the agency to reconsider the proposals, the coalition recommended alternative approaches “to ensure CMS can pursue bad actors without penalizing legitimate providers.”