A broad coalition including providers, suppliers, and beneficiary advocacy organizations is sounding the alarm about the Centers for Medicare and Medicaid Services’ (CMS) proposed changes to Medicare provider enrollment provisions that, though they are included in the Calendar Year (CY) 2027 Home Health Prospective Payment System (PPS) Rule update, would apply to every provider and supplier enrolled in the Medicare program.

In an August 31, 2026 sign-on letter led by LeadingAge to CMS Administrator Dr. Mehmet Oz, the coalition, which includes  the American Hospital Association, the Federation of American Hospitals, the National Association of National Pediatric Nurse Practitioners, the National Rural Health Association—as well as groups representing post-acute care and aging services, such as the American Health Care Association, the National Center for Assisted Living, the National Alliance for Care at Home, and the National Partnership for Healthcare and Hospice Innovation—warns that the proposals, if enacted as proposed, would substantially expand the agency’s denial, revocation, reporting, and related enforcement authorities while removing or failing to establish objective standards and procedural safeguards.

“The foreseeable result is severe enrollment consequences for legitimate providers based on technical errors, conduct outside their control, or broadly defined third-party associations rather than intentional or egregious misconduct,” the letter states. “And when a legitimate provider is removed from Medicare, it is beneficiaries who lose access to care.”

Emphasizing that it “fundamentally supports” CMS’ efforts to protect the Medicare Trust Funds and Medicare beneficiaries from fraud, waste and abuse, the coalition argues that the proposed sweeping changes could expose providers to severe consequences based on various issues, such as clerical errors, documentation discrepancies, circumstances outside their control, or loosely defined associations with third parties, rather than intentional fraud or abuse.

Urging the agency to reconsider the proposals, the coalition recommends alternative approaches “to ensure CMS can pursue bad actors without penalizing legitimate providers.”

Our August 31 press statement reiterates the letter’s message.

LeadingAge firmly believes the provider community is stronger together. We will continue to work with our colleagues to ensure a targeted approach to improving Medicare provider enrollment.

In addition to leading this coalition work, LeadingAge also submitted individual comments on the proposals and the home health payment and quality proposals.