Regulatory Priorities and Positions

NAHC's 2000 Regulatory priorities were established by the membership and reflect the impact of the major legislative and regulatory changes that have swept the home care community over the past several years. Regulatory priorities were determined through a survey of NAHC members. Members were asked to score current issues from "least important" to "most important." The results were tabulated and ranked according to the highest average score. The top twenty home care regulatory priorities for 2000 appear below:

1. PPS: Ensure appropriate case-mix adjuster for PPS
   
   
2. PPS: Provide for appropriate timing of payment to ensure adequate cash flow.
   
   
3. PPS: Ensure equitable national standardized payment rate for PPS.
   
   
4. Fully reimburse agencies for the costs of implementing OASIS and for ongoing data reporting.
   
   
5. Support a definition of homebound that focuses on clinical and functional status and opposes timekeeping requirements.
   
   
6. Allow rebilling of claims denied for technical reasons, in lieu of formal appeals.
   
   
7. Require FIs to make coverage determinations within a reasonable time for claims under prepayment review.
   
   
8. Ensure that provider rights are upheld in fraud and abuse investigations of home health agencies.
   
   
9. Promote consistent application of Medicare coverage rules throughout the country.
   
   
10. Establish minimum training requirements for surveyors and FI reviewers.
    
    
11. Limit medical review to 4% of claims submitted, except in cases of demonstrated cause.
    
    
12. Ensure fairness in implementation of HCFA guidelines for home health and hospice focused medical review.
    
    
13. Ensure statistically valid sampling methodology for post-payment review and overpayment projections.
    
    
14. Increase flexibility in the application of the CoP for non-Medicare patients (e.g., plan of care, OASIS).
    
    
15. Ensure Medicaid access through appropriate home care reimbursement rates.
    
    
16. Guarantee appropriate interest payment to agencies where reimbursement delays are caused by HCFA or the FI.
    
    
17. Modify the definition of a "visit" under the Medicare home health benefit to encourage appropriate use of technological advances in the delivery of home care services (such as telehomecare).
    
    
18. IPS: Grant forgiveness for per-beneficiary limit overpayments where care was necessary and costs reasonable and allow repayment flexibility for home health overpayments.
    
    
19. Promote Medicare-Medicaid coordination for dually eligible patients.
    
    
20. Require reasonable regulations for surety bond requirements (home health) and 117 (HME).
    
    

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