Posts tagged ‘nahc’

October 23, 2012

DH, NAHC alliance will include SHA

I have worked with DecisionHealth for many years across many education venues. This is an exciting opportunity for DecisionHealth and NAHC.

The alliance on education and communication also benefits Selman-Holman Associates! We will be providing ICD-10 education.

Here is some information on the NAHC-DecisionHealth alliance.

WASHINGTON D.C., October 23, 2012— Members of the National Association for Homecare and Hospice (NAHC) will see enhancements to their member benefits in 2013 as a result of a strategic alliance between NAHC and DecisionHealth.

“I am very pleased to announce this alliance with DecisionHealth, a company that has a long and distinguished record in our industry,” said NAHC President Val J. Halamandaris. “This partnership provides an efficient way for us to continue to enhance the depth and breadth of our member benefits while freeing resources to focus further on advocacy.”

Mr. Halamandaris added that the new affiliation covers a broad range of efforts to benefit homecare agencies and hospices, including jointly-produced live events, collaboration on ICD-10 training and education, and preferred discounts for NAHC members on DecisionHealth coding and compliance tools and guidance. The two organizations will also collaborate on offering certification and other professional development programs.

“All of us at DecisionHealth are proud to work with NAHC, the premier advocacy organization for the homecare and hospice community,” said Steve Greenberg, President of DecisionHealth. “We look forward to best-of-breed programs and services that result from our shared expertise and deep understanding of the home care market needs.”

Additional details announced today include:

  • NAHC’s Private Duty Homecare Association of America will collaborate with DecisionHealth to jointly sponsor two conferences next year for leaders of private duty agencies.
  • DecisionHealth will offer discounts for NAHC members on its core coding and compliance products, and its most venerable and longstanding newsletters, Home Health Line and Private Duty Insider.  The latter will expand its coverage to include valuable input from NAHC’s Private Duty Homecare Association of America.
  • The two organizations will launch a series of Home Care ICD-10 Readiness Seminars. These live training events will be designed to assist HHAs with strategic, operational and financial planning to assure seamless transition toward the October 2014 ICD-10-CM mandate.
June 12, 2012

Connolly issues automatic edit for RAP with no CMS Issue Number

The Centers for Medicare & Medicaid Services (CMS) Recovery Audit Contractor (RAC) Connolly recently issued a new RAC issue: RAP claim without corresponding home health claim CMS Issue Number.

The National Association for Home Care & Hospice (NAHC) has requested clarification from CMS about the basis for this since home health Requests for Anticipated Payment (RAP) are supposed to be automatically recovered through the Medicare claims processing system when a home health agency fails to submit a final claim within a certain time period (120 days or 60 days of the RAP payment).

Connolly is the RAC for Alabama, Arkansas, Colorado, Florida, Georgia, Louisiana, Mississippi, New Mexico, North Carolina, Oklahoma, Puerto Rico, South Carolina, Tennessee, Texas, Virgin Islands, Virginia, and West Virginia.

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May 25, 2012

Denials begin for PoC without physician approval

The National Association for Home Care & Hospice (NAHC) recently learned that home health agencies have begun to receive Medicare denials because they provide services and treatments in accord with a plan of care developed after assessing the patient, without obtaining prior approval from the physician for the treatments and services in the plan. In these cases, nurses and therapists conduct patient assessments, initiate care in accord with the referral and create a written plan of care based on assessed needs. They then mail or fax this plan of care to the physician without first receiving approval from the physician for visits and treatments included in the plan of care.

As a result, services that were provided after the initial visit and up to the date of the physician’s signature on the plan of care are denied for lack of physician orders.

The Conditions of Participation (CoP) at 42 CFR 484.18(a) requires that the plan of care be developed in consultation with the agency staff, and that the physician be consulted to approve additions or modifications to the original plan. Further, the CoP require that therapy services include the specific procedures and modalities to be used and the amount, frequency, and duration.

The Medicare coverage rules at 42 CFR § 409.43 specify that the plan of care must contain those items listed in the CoP at 42CFR §484.18(a) and that physician’s orders for services in the plan of care must specify the medical treatments to be furnished as well as the type of home health disciplines that will furnish the ordered services and at what frequency the services will be furnished.

See the Medicare Benefit Policy Manual ( for more specific information, including guidance on oral orders.

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April 6, 2012

OASIS C-1 on the way … and with ICD-10

Thanks to HCLA for letting us know a little about what was said at the recent NAHC conference in Washington DC.
A CMS representative said a new OASIS … C-1 … is in the works.
Pat Sevast of CMS said the revisions are centered about the switch to ICD-10 coding.
While CMS has announced a delay to the implementation of ICD-10, “we are proceeding as if ICD-10 is going to be implemented Oct. 1, 2013,” she said. That’s because CMS’s delay for the new coding set won’t be official until it finishes rulemaking.
August 1, 2011

NAHC pushing for telehealth bill

There are other things going on in Washington besides debt news, and this would should interest us ….

The National Association for Home Care & Hospice (NAHC) is advocating for the Foster Independence Through Technology (FITT) Act of 2011 (S. 501), a bill that would incentivize home care agencies to offer telehealth services.

The measure would, among other things:

  • Create pilot programs to provide incentives for home health agencies to use home monitoring and communications technologies;
  • Provide incentive payments to each participating home care agency equal to a portion of the Medicare savings relative to performance targets.

See the message from NAHC

Here is the background paper, which includes information such as how Veterans’ Affairs saved money with telehealth.

June 17, 2011

NAHC begins face-to-face survey … let’s help!

NAHC is conducting a nationwide physician survey regarding  face-to-face home health requirements. NAHC will be meeting with Medicare soon regarding face-to-face and wants to have as much data as possible.

The survey is attached here and the survey deadline is June 24.

Here is the survey:


March 10, 2011

NAHC receives many responses on face-to-face requirements

This is a brief from NAHC regarding the April 1 enforcement date on face-to-face encounters. I’ll keep you informed on more as I know it …

The implementation of the Medicare face-to-face encounter rules in home health services and hospice continues within the provider, physician, and beneficiary communities as the “dry run” opportunity before the April 1 enforcement date approaches its end (NAHC Report, 1/5/11). The National Association for Home Care & Hospice (NAHC) and a large contingent of supportive stakeholders are continuing their advocacy with the Centers for Medicare & Medicaid Services (CMS) in an attempt to get the rules applied in a sensible and understandable manner. On Monday, NAHC and the other stakeholders engaged CMS via teleconference to review progress on the face-to-face encounters to date, outline unresolved issues, propose further adjustments, and establish remaining action steps for both CMS and stakeholders this month before enforcement is set to begin.

The discussions with CMS involve a deep and dynamic coalition of provider and beneficiary representatives including AARP, the American Medical Association, and the American Hospital Association. Numerous other physician, hospital, case manager, and beneficiary groups are also part of the effort.

The teleconference earlier this week addressed both hospice and home health matters related to the face-to-face encounter requirements. CMS has now released guidance on two crucial hospice issues: (1) the timing requirement for the hospice physician encounter for patients admitted at the start of the third benefit period, and (2) whether the encounter physician must be the same as the terminal illness certifying physician (NAHC Report, 3/2/11).

A number of unresolved home health issues remain, including the nature of the physician documentation required. CMS was presented with a long list of pending questions that need answers or clarification.

A significant focus of the meeting was the results of the ongoing survey that NAHC has conducted since late last week. Home health agencies have responded in unprecedented numbers — to date, NAHC has received over 3,300 survey responses. The information provided is crucial to the efforts to address concerns about the rule, and NAHC thanks all who have provided their input.

A detailed survey report is being developed. However, a preliminary review of the data shows that:

  • Virtually all home health agencies are engaged in serious efforts to educate their staff as well as physicians and patient referral sources both with written materials and in person;
  • There is still an incomplete understanding of the requirements and significant confusion in the physician community, with over two-thirds of agencies reporting that physicians remain confused;
  • Despite the intensive educational efforts of home health agencies and CMS, 66 percent of respondents indicate that physician understanding has not improved and nearly 20 percent report that it has gotten worse;
  • Among the most alarming survey results, 47 percent of agencies report that they deal with physicians who intend to refer patients to other care settings instead of home care because of the face-to-face encounter requirements. Over 35 percent of agencies report that some physicians have indicated that they will refuse to provide the required documentation;
  • The most prevalent concern with physicians is the documentation requirements. Respondents recommend allowing the use of checkboxes (83 percent); eliminating the narrative on homebound status and medical necessity (77 percent); and allowing physicians to use other documents that include the needed information (72 percent); and
  • The survey also indicates that one-third of agencies expect to refuse admission to patients who have not had a qualifying encounter prior to admission, while 80 percent plan to terminate care to those who do not have the qualifying encounter within the 30-day window.

In response to these survey findings, CMS officials asked what more they could do to bring about compliance by April 1. The various responses offered by stakeholders included providing more time before enforcement begins and being more flexible on the documentation requirements.

An additional discussion with CMS is in the process of scheduling for mid-March. NAHC continues to recommend that home health agencies and hospices take advantage of this transition period to test what is working and what is not with respect to the requirements. At this point, the likelihood of sufficient compliance capability by April 1 is in serious doubt. Providers experiencing problems with the face-to-face encounters should continue to report these issues to NAHC. In addition, providers should encourage any physicians with concerns to convey them to CMS directly or through their associations/medical societies.

NAHC is continuing to compile results from the survey received through yesterday and will publish a full report in an upcoming issue of NAHC Report.


Note from Lisa: The links to the NAHC newsletter won’t work here because they are password protected, but I will get the hospice and other information posted soon.

January 18, 2011

MedPAC recommends copays for Medicare home health

Last week the Medicare Payment Advisory Commission (MedPAC) recommended that Congress impose copayments obligation on Medicare home health patients, and that provider payment rates be cut in several ways starting in 2012 and continuing thereafter.

The National Association for Home Care & Hospice (NAHC) strongly disagrees with these ideas and believes that there would be detrimental effects on beneficiaries and that the moves would drive up health care costs.

The MedPAC copayment proposal would require seniors and disabled Medicare beneficiaries to pay a $150 copayment for each 60-day episode of home care where they do not go to a hospital or skilled nursing facility first.

Home health had copayments in the past, but the fees were removed because, among other reasons, there was no evidence copayments saved the government money; some poor seniors could not enter home healthcare, and the costs were transferred to the Medicaid program.

MedPAC also voted to recommend to Congress that home health payment rates be cut beginning in 2012. MedPAC data shows that 35 percent of home health agencies are now paid less than the cost of care and that scheduled cuts will bring that number to nearly 50 percent by 2012.

In its annual March report, MedPAC will deliver its recommendations to Congress.

Interested in having your voice heard on potential copayments? Click here to use the NAHC Legislative Action Network NOW to send this message to your legislators.

Thank you to TAHC for providing some information for this post!

December 31, 2010

CMS answers face-to-face questions

These Q&As answer a lot of questions, including:

  • whether the plan of care and the certification need to be signed by the same physician (not necessarily in home health)
  • whether lead-in phrases are allowed (yes, if the doctor fills out other parts),
  • for patients admitted before January 2011, are face-to-face rules applicable (no!),
  • are electronic signatures acceptable (yes)
  • and more ….

Q: What effect does the face-to-face requirement have on agency practices for meeting Medicare requirements associated with the plan of care and certification?

A: Long-standing Medicare regulations have described the distinct content requirements for the plan of care and certification. The Affordable Care Act (ACA) requires the face-to-face encounter as an additional certification requirement. Many providers have implemented the requirements for the plan of care and certification by using one form which meets all the content requirements of both the plan of care and certification. This approach is perfectly acceptable and it will continue to be acceptable. Several years ago, CMS ceased to require that providers use a specific form for the plan of care and/or certification. Providers have the flexibility to implement the content requirements as best makes sense for them.

Q: Can you please clarify the hospitalist’s role?

A: The statute requires that the certifying physician must document that the face-to-face encounter occurred with himself or herself, or certain non-physician practitioners (NPPs) who inform the certifying physician. Where the patient is admitted to home health from acute or post-acute care, we believe that current practice associated with the home health certification would apply to the face‑to‑face encounter as well. In most cases, we would expect the same physician to refer the patient to home health, order the home health services, certify the beneficiary’s eligibility to receive Medicare home health services, and sign the plan of care. It would be this physician who would be responsible for documenting on the certification that he or she, or a NPP working in collaboration with the certifying physician, had a face–to–face encounter with the patient.

However, we recognize that, in some scenarios, one physician performing all of these functions may not always be feasible. An example of such a scenario would be a patient who is admitted to home health upon hospital discharge. While we would still expect that in most cases, a patient’s primary care physician would be the physician who refers and orders home health services, documents the face‑to‑face encounter, certifies eligibility, and signs the plan of care, there are valid circumstances where this is not feasible for the post-acute patient. For example, some post-acute home health patients have no primary care physician. In other cases, the hospital physician assumes primary responsibility for the patient’s care during the acute stay, and may (or may not) follow the patient for a period of time post-acute.

In circumstances such as these, it is not uncommon practice for the hospital physician to refer a patient to home health, initiate orders and a plan of care, and certify the patient’s eligibility for home health services. In the patient’s hospital discharge plan, we would expect the hospital physician to describe the community physician who would be assuming primary care responsibility for the patient upon discharge.

We also believe that with growing prevalence of NPPs in the acute and post-acute care settings, NPPs may increasingly collaborate with the community certifying physician regarding the NPP’s encounter with the patient in the acute and post-acute settings.

Q: Do both the plan of care and the certification have to be signed by the same physician?

A: Prior to Calendar Year 2011, CMS manual guidance required the same physician to sign the certification and the plan of care. Beginning in Calendar Year 2011, CMS will allow additional flexibility associated with the plan of care when a patient is admitted to home health from an acute or post-acute setting. For such patients, many asked that CMS allow the contact between the physician who attended to the patient during an acute or post-acute stay to satisfy the encounter requirement, even when the physician may not follow the patient in the community. These commenters asked CMS to allow such physicians to inform the community certifying physician as the law allows non-physician practitioners (NPPs) to do.

We are limited by the law that requires the certifying physician to document that the encounter occurred with himself or herself, or a permitted NPP. To adopt as much flexibility as the law allows, we will allow physicians who attend to the patient in acute and post-acute settings to certify the need for home health care based on their face-to-face contact with the patient (which includes documentation of the face-to-face encounter), initiate the orders (plan of care) for home health services, and “hand off” the patient to his or her community-based physician to review and sign off on the plan of care. As we described above, we continue to expect that in most cases the same physician will certify, establish, and sign the plan of care. But the flexibility exists for home health post-acute patients if needed.

Q: Can the physician document the certification when the physician or hospitalist has the patient’s record in front of him?

A: Yes. As long as the face-to-face encounter occurs in the specified timeframe of 90 days prior to the start of care or 30 days after the start of care and the documentation is completed before billing, this scenario is acceptable.

Q: The final rule requires that the certifying physician documents how the clinical findings of the face-to-face encounter support home health eligibility. The rule references homebound status and skilled need. Is the documentation of the clinical findings sufficient?

A: The documentation must include the certifying physician’s synthesis of how the patient’s clinical condition, as seen during the encounter, supports that the patient is homebound and needs skilled services.

Q: Can the home care agency title a document with a lead-in phrase such as: I had a face-to-face encounter on _______ (date). The clinical findings support home health eligibility because:

A: The lead-in phrase is acceptable as long as the physician completes the description of how the clinical findings support homebound status and the need for skilled services, in his or her own words.

Q: Is the face-to-face required for patients in Medicare Advantage plans?

A: No, the face-to-face provision applies only to Medicare fee for service.

Q: Is the face-to-face encounter requirement effective only for patients admitted to home health (i.e. have a new start of care) January 1, 2011 and later?

A: Yes, that is correct. We have interpreted the language in the statute to apply only to certifications and not recertifications.

Q: Will documentation of an encounter submitted via an electronic portal and electronic signatures on face-to-face encounter documentation be acceptable?

A: Yes, that is fine. However, it is important to reiterate that the documentation must be part of the certification itself, or an addendum to it.

Additional information about face-to-face encounter requirements can be found on the NAHC website under the heading “HH PPS 2011 Final Regulation” at

December 14, 2010

Check box does not meet F2F requirements, but labels might

These questions are the Q&As from NAHC from questions that the organization has received on the face-to-face encounter issue.

Question:  Clarify the regulatory requirement of no standardized language. To be used in documentation of F2F are we able to create a form that contains check box options for the physicians in regards to diagnosis, etc.?
Answer: A check box would not meet CMS’ intent since the agency would be providing prescribed verbiage that a physician must choose from. This “standardized” language may not fit with the clinical condition of the patient. The full text from CMS in the Federal Register reads: “The law requires this as a condition for HH payment. We proposed that the documentation of the encounter be a separate and distinct section of, or an addendum to, the certification, and that the documentation include why the clinical findings of the encounter support HH eligibility. We believe that our proposed documentation requirements meet the Congress’ intent for more physician involvement in determining the patient’s eligibility and managing the care plan. We believe that were we to allow the HHA to craft standard language which the physician would then simply sign, we would not achieve the sort of physician involvement in the eligibility determination and care plan which was the Congress’ intent. As such, we believe that if a HHA were to develop standardized encounter language to be signed by the physician, they would not be adhering to the statutory payment requirements that the “physician document” the encounter.”

Question:  May a home health agency put labels on a form for the physician to complete?
Answer: When asked if it would, however, be acceptable for the agency to at least label the section of the 485 or addendum where the physician’s documentation should be placed, titling it for example “Physician Verification of Face-to-Face Encounter,” and then to include subheadings which include: Date of Encounter, Medical Condition for Encounter, Services Needed, Clinical Findings, Homebound Status, Physician Signature, Date. CMS responded Yes, this is fine.  As long as the info/clinical findings and how the findings support eligibility are documented by the physician, in his/her own words.

Question:   If a hospitalist documents the F2F and certifies the patient, is the primary physician (who will sign the 485 and oversee the episode of care) required to complete a face to face as well?  Or does the hospitalists F2F meet the requirement?
Answer: No, a second face-to-face by the physician ordering services and signing the plan of care is not required.

Question:   If a F2F encounter occurred within the past 90 days prior to referral for homecare and the reason for the F2F was not related to the homecare referral we must then get an additional F2F encounter documented?
Answer: Yes a second encounter will be required.

Question:   I thought the face to face for homecare was effective for admissions as of 1/1/11?
Answer: The face-to-face encounter is required for any patient with a Start of Care Medicare fee-for-service episode 1/1/11 and after. It is not required for recertification episodes.


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