The 2,900 California Agencies Medicare Forgot to Count
CMS asked OMB on Friday for emergency clearance to put California home health under the Review Choice Demonstration, citing significant fraud. California billed $3.26 billion in CY2024, seventy percent of the six states already in the program, and the burden estimate attached to the request does not move by a single hour. That is because the hour count was never a count of anything: CMS built it by multiplying a postage bill by half an hour, and the notice carries the same number to a seventh state.
On September 1, 2023, CMS posted a paragraph to a web page and put Oklahoma into the home health Review Choice Demonstration.
The selection window opened six weeks later. The first cycle started December 1.
That paragraph is the entire public process for moving a state's home health agencies onto 100 percent claim review.
Friday morning CMS filed to do it to California.
The vehicle is a Paperwork Reduction Act notice, document identifier CMS-10599, on public inspection at 8:45 am Eastern and publishing Monday. It asks OMB for emergency clearance, the lane reserved for collections where "public harm is reasonably likely to occur if normal, non-emergency clearance procedures are followed." The harm CMS names is "the continuation of significant fraud found in the traditional Medicare home health benefit in California."
California billed Medicare $3,264,178,716 for home health in CY2024, across 1,339,384 thirty-day periods and 360,970 beneficiaries. That is 20.8 percent of the entire national home health benefit and the largest figure any state posts. The six states already inside the demonstration billed $4.64 billion between them, so California on its own is 70.3 percent of the program it is joining and 50.7 percent of its claim volume (chart below).

There are 2,900 Medicare-enrolled home health agencies in California on the October 1 provider file, more than any other state carries and nearly seven in ten of every agency its own contractor serves. The notice sets its respondent count at 4,700, which is the number the approved collection has carried since last December.
"How do you add the country's largest home health market and leave every number in the burden estimate where it was?"
The rest of this brief is for subscribers.
The impact tables, the code-level detail, and the rest of the analysis sit past this line.
$50 a month, or $500 a year.
Already a subscriber? Sign in