The American Association for Homecare (AAHomecare) is preparing to comment on the Calendar Year 2026 Home Health Prospective Payment System proposed rule, published in the Federal Register on July 2.
The association’s regulatory council said in a July 23 update to stakeholders that it’s “refining messages and guidance to inform industry comments” on a number of issues in the proposed rule.
— Single-payment amount in competitive bidding: The Centers for Medicare & Medicaid Services (CMS) has proposed setting the single-payment amount (SPA) at the 75th percentile of winning bids when the Medicare competitive bidding program resumes. That SPA would result in “potentially driving rates below sustainable and market-reflective levels,” AAHomecare said.
— Expanding competitive bidding to include medical supplies: CMS wants to add medical supplies — including 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,” AAHomecare said.
— No supplier experience consideration: The proposed rule includes a process to evaluate supplier capacity, but “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; no guarantees for small suppliers: AAHomecare said the proposed methodology for determining the number of winning bidders arbitrarily limits the total number of suppliers and fails to guarantee 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 sort of provision is missing from the proposed rule.
— Annual accreditation for providers who bill Medicare: The proposed rule would require providers who bill Medicare to be reaccredited yearly, 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.”
— 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.”
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.”
