ASE Joins Comments on the CY 2027 Home Health Prospective Payment System Proposed Rule

On August 21, ASE joined the Alliance of Specialty Medicine in comments to CMS Administrator Mehmet Oz on the Medicare provider enrollment provisions of the proposed CY 2027 Home Health Prospective Payment System rule. The letter raises concerns across a broad set of proposals: expanded retroactive revocation authority, new revocation and denial grounds tied to third parties’ Medicare debt or adverse actions, a geographic “excessive number of providers” revocation standard, denial based on sharing office space with a revoked or denied provider, an expanded reapplication bar and preclusion list reaching owners’ and managers’ convictions, a broadened “managing employee” definition covering medical directors and other clinical titles, and elimination of the five-year lookback on affiliation reporting. Across each, the Alliance asks CMS to limit enforcement to conduct involving actual fraud or control, define key terms objectively, and provide notice and due process before imposing consequences.

This letter builds on and extends the concerns ASE raised in its own comments on the same rule, reinforcing a consistent position that program integrity tools should target genuine bad actors rather than sweep in physicians and practices with no real control over the conduct at issue. Because echocardiography practices commonly involve medical directors, shared office space, and routine vendor relationships, the Alliance’s broader coalition letter strengthens ASE’s individual advocacy by showing unified opposition across specialty medicine to enforcement authorities that could otherwise expose good-faith echo labs and their physician leaders to retroactive recoupment or enrollment denial.