Mehmet Oz, MD, MBA
Administrator
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850
Re: Calendar Year 2027 Home Health Prospective Payment System (HH PPS) Rate Update; Requirements for the HH Quality Reporting Program and the Expanded HH Value-Based Purchasing Model; Medicare Provider Enrollment, Durable Medical Equipment (DME), and DME, Prosthetics, Orthotics, and Supplies (DMEPOS) Policies [CMS-1844-P]
Dear Administrator Oz:
The Alliance of Specialty Medicine (the “Alliance”), representing more than 100,000 specialty physicians from fifteen specialty and subspecialty societies, is deeply committed to improving access to specialty medical care by advancing sound health policy. On behalf of the undersigned members, we write to provide feedback on specific Medicare provider enrollment proposals included in the aforementioned proposed rule.
Revocations and Denials of Enrollment
Modifications of Current Revocation Provisions
CMS proposes several modifications to its existing revocation authorities to provide greater flexibility in addressing provider enrollment issues, and with the goal of strengthening program integrity and better addressing fraudulent, abusive, and non-compliant providers. Specifically, CMS proposes to remove the existing factors used to determine whether a provider has engaged in a pattern or practice of submitting claims that fail to meet Medicare requirements; expand revocation authority based on false or misleading information submitted on or associated with any CMS or Medicare enrollment-related form; extend revocation authority across a provider’s other Medicare enrollments when one enrollment is denied; and significantly expand the circumstances under which revocations may be applied retroactively.
Click to view the full Alliance of Specialty Medicine Comments on HH PPS (CMS-1844-P)
