The American Association for Homecare (AAHomecare) has announced the issues it will prioritize when commenting on the Calendar Year 2026 Home Health Prospective Payment System proposed rule, published in the Federal Register on July 2.
In a July 23 update to stakeholders, the association indicated that its regulatory council has identified a number of key issues and is “refining messages and guidance to inform industry comments.”
AAHomecare is prioritizing these concerns:
— Single-payment amount in competitive bidding: AAHomecare said the Centers for Medicare & Medicaid Services (CMS) has proposed setting the single-payment amount (SPA) at the 75th percentile of winning bids when it restarts the Medicare competitive bidding program. That SPA would result in “potentially driving rates below sustainable and market-reflective levels,” AAHomecare said.
— Expanding competitive bidding to include medical supplies: CMS also wants to add medical supplies such as urological, ostomy and tracheostomy supplies to the competitive bidding program, though “it has been commonly understood” that such items “do not meet the definition of ‘medical equipment items’ and therefore are not eligible to be included in the competitive bidding program,” the association said.
— Adding CGMs, insulin pumps to competitive bidding: The proposed rule would subject continuous glucose monitors (CGMs) and insulin pumps to competitive bidding, which “raises significant concerns given the limited number of manufacturers and the evolving nature of the technology,” the association said. “We believe further evaluation is needed to ensure patient access isn’t impacted by adding these products to the competitive bidding program.”
— No supplier experience consideration: While the proposed rule includes a process to evaluate supplier capacity, “it does not appear to consider a supplier’s experience, either in the product category or within a specific bidding area,” AAHomecare said.
— Arbitrary limit on number of winning suppliers, with no provision to guarantee small supplier participation: AAHomecare said the proposed methodology for determining the number of winning bidders arbitrarily limits the total number of suppliers and also fails to affirm that small suppliers will be able to participate. “CMS is statutorily required to provide small suppliers a fair opportunity to be considered for participation in the DMEPOS competitive bidding program, and CMS has historically aimed to target at least 30% of contract awards to go to small suppliers,” AAHomecare said. That provision is missing from the proposed rule.
— Annual accreditation for providers billing Medicare: The proposed rule would require providers who bill Medicare to be reaccredited every year, a process that would be “logistically unworkable for accrediting organizations and suppliers,” AAHomecare said. “It is not clear that such [a] requirement will have a meaningful reduction in fraud and abuse by fraudsters exploiting the Medicare program. While we support CMS’s commitment to program integrity, we believe there are alternative approaches that would strengthen oversight without imposing additional burdens.”
Public comments on the proposed rule are due by Aug. 29. AAHomecare shared a work-in-progress document and said it would share its final version “in the coming weeks.”
