WASHINGTON, July 6, 2012—In a letter to the Senate Finance Committee, the American Association for Homecare recommended that the Centers for Medicare & Medicaid Services (CMS) refocus its strategy for fighting fraud.

In the letter, AAHomecare called Medicare’s fraud-fighting system confusing, ambiguous, subjective and unfair. It places excessive burdens on the HME industry, the association said. AAHomecare made these recommendations:

• Conduct independent reviews of Medicare contractors to hold them accountable.
• Establish clear, unambiguous medical policies for HME.
• Enhance review of HME providers who do not respond to audit requests.
• Establish limitations on the number of audits an HME provider can receive during a given time period.
• Reinstate the “clinical inference” policy.
• Require that electronic health records systems include elements for HME medical necessity documentation.
• Mandate use of an electronic clinical medical necessity template.
• Mandate use of a template in the power mobility device (PMD) prior authorization demonstration.
• Provide additional physician education on medical necessity requirements.
• Establish a definitive policy prohibiting retroactive implementation of policies.

The Senate committee has been collecting comments about ways CMS can improve its system for eliminating fraud.