AAPM&R is urging CMS to rethink sweeping proposed changes to Medicare provider enrollment requirements that could create significant administrative and financial burdens for rehabilitation physicians, ultimately disrupting care for Medicare beneficiaries. In the Academy’s comments in response to the Calendar Year (“CY”) 2027 Home Health Prospective Payment System proposed rule, we emphasized that AAPM&R supports strong safeguards against fraud, waste, and abuse but cautioned that several of CMS’s proposals lack adequate transparency, predictability, proportionality, and procedural protections. The Academy is particularly concerned that the proposals do not distinguish between intentional fraud and isolated or technical enrollment errors that pose little risk to the Medicare program or its beneficiaries.
The stakes are especially high for patients receiving rehabilitation care, who often require continuous, coordinated treatment following life-changing events such as spinal cord injury, stroke, or brain injury. AAPM&R warned that unnecessary enrollment revocations, retroactive recoupments, and lengthy bars to reenroll in the Medicare program could drive providers out of Medicare and interrupt patient care.
Among other recommendations, the Academy urged CMS to retain the current 60-day period for submitting claims after revocation rather than reducing it to 15 days; preserve prospective revocation rather than allowing broad retroactive revocation; retain the existing factors used to distinguish serious billing abuse from technical errors; and reject enrollment sanctions based solely on geographic provider concentration or sharing office space with another practitioner. AAPM&R also opposed expanding the 10-year reapplication bar to technical or good-faith errors and urged CMS to establish a clear nexus before imposing enrollment sanctions on one entity based on a separate but related entity’s disenrollment.
AAPM&R’s message to CMS is straightforward: Medicare program integrity should not come at the expense of access to medically necessary rehabilitation and physician services. The Academy is encouraging CMS to adopt targeted, proportionate enrollment safeguards that address genuine program integrity risks without penalizing compliant providers or creating unnecessary disruptions in care for vulnerable Medicare beneficiaries.