Letter to the Editor: Amedisys CEO Paul Kusserow Pushes Back on Improper Payment Reports

Your article, “CMS Made $3.2 Billion in Improper Home Health Payments in 2018,” deserves a headline that draws readers’ attention to the real story here.

Only in the next-to-last sentence does the piece mention the most telling data point — namely, that improper home health payments “plummeted dramatically” between 2015 and 2018 from 59% of all such reimbursements to 18%.

In short, you buried the lead.


While there’s more to be done, the work of CMS and the industry since 2015 now has us swiftly and aggressively moving in the right direction as clearly evidenced by the drop of 41% points in the home health error rate. Given these facts, I think your readers would have benefited from a focus on the significant reduction in the improper payment rate along with the drivers of the improper payment rates.

As you mentioned, the vast majority of improper payments are attributable to improper documentation, not eligibility issues like homebound status, medical necessity and the like. Many are not aware of this and perceive the improper payment rate as driven primarily by fraud.

I think all would benefit from information and a discussion of the declining improper payment rate and issues that still persist in the industry around proper documentation.


For example, the introduction of face-to-face requirements by CMS in 2011 contributed significantly to the initial, dramatic rise in improper payments that peaked in 2015. As the GAO report states, “CMS officials told us that documentation requirements for the face-to-face examination policy for home health services in particular led to an increase in insufficient documentation.”

We agree with the report’s recommendation that CMS should “routinely assess, and take steps to ensure, as appropriate, that Medicare and Medicaid documentation requirements are necessary and effective.”

The value of home care is well established with proven cost savings, better outcomes and innovations in patient care being demonstrated every day. We look forward to working with CMS and others to ensure the rate of improper payments continues to decline. In closing, I hope that you will continue your interest in the improper payment rate and report on our collective progress in reducing it for taxpayers.

By Paul Kusserow, president and CEO of Amedisys

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