AAHomecare to CMS: Target Real Fraud, Educate on Honest Errors

Last week, AAHomecare submitted comments to the Request for Information - Fraud Defense Contracts (RFI). In the RFI, CMS asked industry for ideas on how to redesign its Medicare program integrity contracting with “Fraud Defense Contracts.” Under the new model, CMS would take a bigger role in lead development, prioritization, and law enforcement vetting, while contractors would focus on working CMS-assigned fraud investigations and supporting administrative and enforcement actions such as payment suspensions, revocations, and referrals.

In AAHomecare’s comments, the Association urged CMS to keep true fraud investigation separate from routine compliance, where unintentional documentation errors would go to the DME MACs for education. The comments also call for:

• Better site-inspector quality.
• Real-time coordination with Medicare Advantage and Medicaid on revocations and reinstatements.
• Contractor performance measured by fraud findings that hold up on appeal, rather than audit volume or dollars identified.

AAHomecare developed an overview document of all the recommendations the Associations has made regarding fraud, waste, and abuse. You can find the document here.