When the proposed rule was released in May, we summarized the concept for members noting that LeadingAge recognizes that CMS must find ways to identify and combat fraud. However, instituting a “choice” demonstration that will likely harm beneficiaries and impede access to care is not the solution. According to CMS the demonstration would help make sure that payments for home health services are appropriate through either pre-claim or post-payment review, thereby working towards the prevention and identification of potential fraud, waste, and abuse. CMS proposes initially implementing the demonstration in Illinois, Ohio, North Carolina, Florida, and Texas with the option to expand to other states in the Palmetto/JM jurisdiction. The demonstration is proposed to start in Illinois on December 10, 2018. That is somewhat delayed compared to the earlier October 1, 2018 proposed implementation. Additional comments are being solicited through October 29, 2018 and can be emailed to OIRA_submission@omb.eop.gov.