LeadingAge and the National Partnership for Healthcare and Hospice Innovation (NHPI) proposed audit targeting criteria for CMS to use which could reveal, through claims-based measures, actions that are suggestive of profiteering behavior and malfeasance as opposed to the current focus on recouping payment for inadvertent billing and technical errors. These recommendations were sent to staff at the Centers for Medicare and Medicaid Services, Center for Program integrity on January 8, 2025.