The Alliance submitted comments to CMS in response to its request for comments on Pre-Claim Review Demonstration for Home Health Services. While the Alliance understands that the rationale for bringing this failed demonstration project back is to address issues of fraud and abuse, we noted in comments that the policy would create a significant administrative burden on home health agencies. Most concerningly, it would have a tremendous negative impact on the access to care for beneficiaries in order for CMS to target a few “bad apples.”

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