The Alliance submitted comments to CMS on September 28 regarding the proposed PPS rate update for 2010. In the comments, the Alliance recommended that CMS delay OASIS-C implementation and the new HHCAHPS to give agencies additional time to prepare for these changes. We also recommended that CMS rely on targeted fraud enforcement activities rather than across-the-board cuts to weed out abusive providers. See our comments here.
Thanks to the members of the Alliance’s Clinical Directors, Reimbursement, and QI Committees for their assistance in developing our comments.
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