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WiAHC Submits Comments to DHS Supporting Removal of Professional Advisory Bodies from State Regulations

July 23, 2025 9:38 AM | Account Administrator (Administrator)

For the last several years, WiAHC has been advocating to eliminate an outdated state regulation relating to professional advisory bodies for home health care agencies. WiAHC has been advocating for this change since professional advisory committees were removed from federal regulations in 2017, as home health agencies are already overseen by a governing body pursuant to federal regulations.  In addition, home health agencies are also overseen by governing bodies in Wisconsin regulations.  In 2017, the federal Centers for Medicare & Medicaid Services (CMS) also put in place federal regulations requiring home health agencies to implement ongoing quality assessment and performance improvement (QAPI) programs.  Essentially, CMS replaced professional advisory committees in federal regulations with the creation of the QAPI program.

In January 2023, WiAHC formally requested that DHS eliminate professional advisory bodies for home health care agencies in the agency’s biennial rules review – a process by which DHS makes technical changes and updates to existing state regulations. Our organization’s rationale is that this would bring Wisconsin’s regulations in line with federal regulations for the reasons addressed above.

Subsequently, the draft DHS biennial rules review document includes the elimination of professional advisory bodies for home health agencies. On July 7, the agency formally requested public comments on the economic impact of the draft biennial rules review. In anticipation of this announcement, WiAHC had requested appropriate feedback from home health agency member employees. (Thank you to those who provided feedback!)  WiAHC incorporated this feedback into our formal comment letter, which has been submitted to DHS. Further updates will be included in future editions of this newsletter.


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