AAHomecare Emphasizes Need for Nuanced & Strategic Approach to Targeting Fraud
WASHINGTON, D.C. – Last week, AAHomecare submitted formal comments in response to CMS’ Request for Information (RFI) Related to Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH). The RFI sought stakeholder input on potential policy, operational, and technology-based solutions to improve fraud prevention.
In its submission, AAHomecare emphasized that to ensure any fraud fighting efforts are successful without inadvertently harming patients and the legitimate DMEPOS supplier community, CMS needs to adopt a more nuanced and strategic approach that targets at-risk and bad actors while minimizing the administrative burden on ethical suppliers.
Below are some key recommendations made in the comments:
Enhancing Provider Enrollment Requirements for New Suppliers
To prevent fraudulent entities from cycling through the Medicare system, AAHomecare recommended implementing a robust identity verification and authentication process to ensure bad actors cannot enter or re-enter under new company names.
Improving Audit Program
New suppliers should immediately be required to be in a Targeted Probe and Education (TPE) and all audit contractors should operate within their scope of work and coordinate on projects.
Improving Cross-Program Communication and Enforcement
If a company is revoked from Medicare, the revocation should be applied across all government healthcare programs. Enhancing communication between the payers will limit fraudulent actors from moving around within the healthcare programs.
Promoting Technology Solutions
Expanding electronic ordering, data-sharing capabilities, and using CMS’ authority to conduct a proof of concept to implement a real-time verification tool.
Our comments were informed by member experiences and ongoing discussions with CMS on fraud and abuse within the DMEPOS sector. We appreciate the valuable insights shared by members, which helped shape a thoughtful and practical response to CMS. We will continue to collaborate with CMS on their program integrity efforts and advocate on behalf of the industry for a balanced approach that will protect patient access. See AAHomecare’s comments here.
EDITORIAL: Face-to-Face Engagement with the Administration Remains a Priority
WASHINGTON, D.C. – AAHomecare’s Tom Ryan, Jay Witter, and Kim Brummett, along with consultants Cara Bachenheimer and Tom Barker, met last week with the White House Office of Management and Budget to discuss industry advocacy priorities including the flawed RID competitive bidding framework for medical supplies and diabetes products, the recently announced moratorium on new suppliers and location enrollments, and how the DMEPOS community can be a strong partner in combatting Medicare fraud.
This week’s meeting follows other face-to-face meetings in March with senior White House health policy advisors (joined by Chairman Josh Marx), Medicare program leadership at CMS, and the Small Business Administration’s Office of Advocacy. Several members of our team also met virtually with the HHS Office of Inspector General to discuss fraud prevention last week, as well.
The priorities and messaging for each meeting varies depending on who we are engaging but one consistent point is highlighted every time: the home medical equipment community is committed to working with Federal policymakers to strengthen access to critically needed DMEPOS products and services.
Last Fall, AAHomecare had several opportunities to meet with the Administration related to last year’s DMEPOS/Home Health Rule, and they remain open to hearing from us directly. While we can’t promise that our latest meetings will result in more wins like the decision to keep legacy products out of the next bidding round, we are encouraged that leaders in the White House, CMS, and other Federal agencies are willing to engage. Be assured that AAHomecare is going to continue to take advantage of every opportunity to meet with these policymakers and make the case for your business and the patients and caregivers you support.
