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Press Release | Home Health, Medicaid, Medicare

NAHC Statement on CMS Announcement Restarting Pre-Claim Review

May 31, 2018


For additional information:

Thomas Threlkeld
Deputy Director of Policy & Communications

Washington, D.C., May 31, 2018: 

On May 29, the Centers for Medicare and Medicaid Services (CMS) announced the restarting of a demonstration program that involves a greatly expanded review of Medicare home health claims in certain target states. The program, Pre-Claim Review Demonstration for Home Health Services (PCRD), originally started in August 2016 in Illinois. It was suspended effective March 30 without expansion into other targeted states. The revised PCRD slightly modifies the program in three ways:

  1. The targeted states have been partly changed to include Illinois, Texas, Florida, Ohio, and North Carolina while dropping Michigan and Massachusetts;
  2. Home health agencies (HHAs) are given a choice of 100% pre-claim review, 100% post-payment review, or a 25% payment rate reduction and potential claim review by the Recovery Audit Contractor; and
  3. HHAs can qualify for an exemption based on certain, unstated performance standards.

“The return of pre-claim revenue, even with revisions, is premature and may be entirely unnecessary,” stated William A. Dombi, president of the National Association for Home Care & Hospice. “CMS has not taken advantage of what it learned during PCRD in Illinois in 2016-2017 where claims errors that related to documentation were ultimately correctible,” he added. “The home care community also presented multiple and less burdensome alternatives to CMS that we believe will be equally or more effective than pre-claim review. CMS has not pursued or considered any of those alternatives,” Dombi stated.  “It would be prudent for CMS to look to these alternatives before requiring home health agencies to take staff away from patient care to chase after endless paperwork.   The Illinois experience demonstrated that any concern is limited to correctable paperwork errors.”

In response to the CMS announcement, NAHC and its partnering state home care associations have initiated advocacy efforts to secure public release of all the data from the original project, conduct a thorough evaluation of the outcomes from that project, evaluate the best alternatives to pre-claim review that can address any deficiencies uncovered through the project, and institute appropriate corrective measures that do not needlessly increase administrative burdens and costs of care. “We cannot accept any new regulatory burdens that waste precious clinical resources that should be devoted to patient care, not a paper-chase,” stated Dombi. “While the home care community has been a leader in developing effective program integrity measures, CMS has fallen far short of justifying a restart of this burdensome program. We must oppose it and strongly recommend that CMS open the promised discussions on viable alternatives,” he added.


About:  The National Association for Home Care & Hospice (NAHC) is the voice of home care and hospice.  NAHC represents the nation’s 33,000 home care and hospice providers, along with the more than two million nurses, therapists, and aides they employ.  These caregivers provide vital services to Americans who are aged, disabled, and ill.  Some 12 million patients depend on home care and hospice providers, who depend on NAHC for the best in advocacy, education, and information.  NAHC is a nonprofit organization that helps its members maintain the highest standards of care.  To learn more about NAHC, visit