Regulations & Analysis
AAHomecare’s Regulatory Affairs team monitors, evaluates, and responds to the steady stream of new and updated rules, as well as other guidance, from CMS, HHS, and other Federal agencies. Priorities include protecting HME interests in future competitive bidding rounds, limiting overly burdensome authorization and audit practices, and expanding coverage for medically necessary home medical equipment.
Below you will find our analysis of proposed rules and our related official comments, along with coverage of reports, guidance, audit policies, and other information impacting the homecare sector and the patients and communities we serve.
2023
- Home Health Proposed Rule/DME Provisions Summary – July 2023
- Transitional Coverage for Emerging Technologies Issue Summary – June 2023
- Supplier Tracking Data – June 2023 update
- CMS 2024 Medicare Advantage and Part D Final Rule Summary – Apr. 2023
- COVID-19: CMS Instruction to not use the CR Modifier & DR Condition Code After Public Health Emergency – Apr. 2023
- Comments on CMS Proposed Decision Memo: Seat Elevation Systems as an Accessory to Power Wheelchairs (Group 3) – Mar. 2023
- Comments on CMS-0057-P: Medicare and Medicaid Programs; Patient Protection and Affordable Care Act; Advancing Interoperability and Improving Prior Authorization Processes for MA Organizations, Medicaid Managed Care Plans, State Medicaid Agencies, CHIP, and more – Mar. 2023
- Comments on Proposed LCD; Glucose Monitors (DL33822) Regarding the End of the COVID-19 Public Health Emergency – Feb. 2023
- Supplier Tracking Data – Feb. 2023 update
CMS Should Instead Take Action to Ensure Beneficiaries Have Access to the Appropriate Intermittent Catheter – response to OIG Report on Urological Supplies – Jan. 2023 - Improving Care for Patients Jointly Enrolled in Medicare and Medicaid (Dual-Eligibles) – letter to selected U.S. Senators – Jan. 2023
2022
- 2023 Fee Schedule Analysis for Top 25 DME Items: Former CBAs and Rural/Non-Rural Areas (Excel Spreadsheets) – Dec. 2023
- Comments on CMS "Make Your Voice Heard" RFI Covering Multiple Issues – Nov. 2022
- Supplier Tracking Data – Nov. 2022
- Comments on CMS National Coverage Analysis for Seat Elevation Systems as an
Accessory to Power Wheelchairs (Group 3) Introduction – Sept. 2022 - AAHomecare/NCART Response to OIG PMD Report – Sept. 2022
- Comments on Medicare Advantage RFI and Related Talking Points – Aug. 2022
- Supplier Tracking Data – July 2022
- FAQ on FDA Emergency Use Authorization for Ventilators and Other Respiratory Devices – June 2022
- AAHomecare OIG PMD Repairs Report Summary – June 2022
- Supplier Tracking Data – May 2022
- RFI Comments: Electronic Prior Authorization Standards, Implementation
Specifications, and Certification Criteria – Mar. 2022 - Comments on FDA Guidance: Transition Plan for Medical Devices Issued Under Enforcement Polices & EUAs During COVID-19 PHE – Mar. 2022
- ALJ Appeal Update – Mar. 2022
- AAHomecare Comments to House Republican Healthy Task Force – Mar. 2022
- Supplier Tracking Data – Mar. 2022
- AAH OIG Hospice Data Brief Summary – Feb. 2022
- Summary: Medicare Program; Updates to Lists Related to DMEPOS Conditions of Payment [CMS-6081-N] – Jan. 2022
2021
- 2021 Regulatory Affairs Accomplishments
- AAH CMS MCIT Comments 1021
- AAH CMS-1738-F SUMMARY 0122
- AAH CMS-1751-P EN NCD Comments 0921
- AAH CMS-3372-P MCIT and RN comments
- AAH comments to CMS on Proposed NCD Home Oxygen 0721
- AAH Glucose Monitors LCD Comments
- AAH MCIT RN Summary (CMS-3372-F)
- AAH Medicaid PA CMS-9123-P Comments
- AAH OIG CERT Report Summary
- AAH OIG Hospice Overpayment Summary
- AAH OSHA ETS Summary 122121
- AAH Proposed EN LCD PA Comments
- AAH Proposed NCD Home Oxygen Comments
- AAH to CMS re Proposed DME Rule June 2021
- AAH to DME MACs - Respiratory Recall - June 2021
- Letter to CMS in support of QIC demo final 110121
2020
- 1.2020 FAR WEST RATE ANALYSIS
- 1.2020 GREAT LAKES RATE ANALYSIS
- 1.2020 MIDEAST RATE ANALYSIS
- 1.2020 NEW ENGLAND RATE ANALYSIS
- 1.2020 PLAINS RATE ANALYSIS
- 1.2020 ROCKY MOUNTAIN RATE ANALYSIS
- 1.2020 SOUTHEAST RATE ANALYSIS
- 1.2020 SOUTHWEST RATE ANALYSIS
- 2020 Regulatory Wins
- AAH CMS-1738-P Comments
- AAH CMS-3372-P MCIT - RN comments.pdf
- AAH CMS-5531-IFC Comments 062420
- AAH MEDCAC Comments 062220
- AAH PFS Comments CMS-1734-P 092120
- AAH Response to FY21 President's Proposed Budget
- AAH Supplemental CMS-1738-P Comments
- AAH Urological Supplies LCD Comments
- FAR WEST CARES RELIEF 050420
- GREAT LAKES CARES RELIEF 050420
- MIDEAST CARES RELIEF 050420
- NEW ENGLAND CARES RELIEF 050420
- PLAINS CARES RELIEF 050420
- ROCKY MTN CARES RELIEF 050420
- SOUTHEAST CARES RELIEF 050420
- SOUTHWEST CARES RELIEF 050420
- Telehealth Task Force Survey AAH Responses
2019
- 2019 Regulatory Wins
- AAH AKS Comments 1219
- AAH Bona Fide Bid Analysis Recommendations
- AAH CBP Survey RFI Comments
- AAH CMN PRA Comments
- AAH CMS-1713-F ESRD SUMMARY
- AAH CMS-1720-P Comments 1219
- AAH CMS-6058-FC Comments
- AAH Comment Letter Medicaid Managed Care Proposed Rule CMS2408P
- AAH Equal Access Provision Comments CMS-2406-P2
- AAH GAO IMPROPER PAYMENT Summary
- AAH HIPAA RFI Comments
- AAH RFI Comments
- AAH RFI PI Comments
- AAH WM RFI Comments
2018
- DMEPOS Appeals Represent 57% of Total ALJ Appeals
- New Supplier Tracking
- AAH CMS RFI Cures Medicaid Comments
- AAH CMS-1687-IFC Comments
- AAH CMS-1691-F Summary
- AAH CMS-1720-NC Stark Law Comments
- AAH Comment Letter Medicaid managed Care Proposed Rule CMS2408P
- AAH Comment Letter Proposed Rule RIN 2900-AP02 Veterans Affairs
- AAH Comment Letter Secretary AZAR Presidents Budget 0618
- AAH Comments DAB RFI Precedential Decisions
- AAH Comments MedPAC June 2018 Report to Congress
- AAH Comments MUE Proposed Edits February 2018
- AAH Comments PMD PRA 032018
- AAH Competitive Bidding Reform Letter
- AAH ESRD 2018 PR Comments
- AAH GAO CBP
- AAH Ventilator CBP Comments
- AAHomecare additional comments to CMS on July 2018 NPRM