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National Association for Home Care & Hospice
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In the various roles he has undertaken through the years, Val J. Halamandaris has been a singular driving force behind the policy and program initiatives resulting in the recognition of home health care as a viable alternative to institutionalization. His dedication to consumer advocacy, which enhances the quality of life and dignity of those receiving home health care, merits VNA HealthCare Group’s highest recognition and deepest respect. 

VNA HealthCare Group

I have the highest respect for them, especially for the nurses, aides and therapists, who devote their lives to caring for people with disabilities, the infirm and dying Americans.  There are few more noble professions.

President Barack Obama

Home health care agencies do such a wonderful job in this country helping people to be able to remain at home and allowing them to receive services

U.S. Senator Debbie Stabenow (D-MI) Chair, Democratic Steering and Outreach Committee

Home care is a combination of compassion and efficiency.  It is less expensive than institutional care...but at the same time it is a more caring, human, intimate experience, and therefore it has a greater human’s a big mistake not to try to maximize it and find ways to give people the home care option over either nursing homes, hospitals or other institutions

Former Speaker of the U.S. House of Representatives Newt Gingrich (R-GA)

Medicaid covers long-term care, but only for low-income families.  And Medicare only pays for care that is connected to a hospital discharge....our health care system must cover these vital services...[and] we should promote home-based care, which most people prefer, instead of the institutional care that we emphasize now.

Former U.S. Senator Majority Leader Tom Daschle (D-CD)

We need incentives to...keep people in home health care settings...It’s dramatically less expensive than long term care.

U.S. Senator John McCain (R-AZ)


Home care is clearly the wave of the future. It’s clearly where patients want to be cared for. I come from an ethnic family and when a member of our family is severely ill, we would never consider taking them to get institutional care. That’s true of many families for both cultural and financial reasons. If patients have a choice of where they want to be cared for, where it’s done the right way, they choose home.

Donna Shalala, former Secretary of Health and Human Services

A couple of years ago, I spent a little bit of time with the National Association for Home Care & Hospice and its president, Val J. Halamandaris, and I was just blown away. What impressed me so much was that they talked about what they do as opposed to just the strategies of how to deal with Washington or Sacramento or Albany or whatever the case may be. Val is a fanatic about care, and it comes through in every way known to mankind. It comes through in the speakers he invites to their events; it comes through in all the stuff he shares.

Tom Peters, author of In Search of Excellence

Val’s home care organization brings thousands of caregivers together into a dynamic organization that provides them with valuable resources and tools to be even better in their important work. He helps them build self-esteem, which leads to self-motivation.

Mike Vance, former Dean of Disney and author of Think Out of the Box

Val is one of the greatest advocates for seniors in America. He goes beyond the call of duty every time.

Arthur S. Flemming, former Secretary of Health, Education, and Welfare

Val has brought the problems, the challenges, and the opportunities out in the open for everyone to look at. He is a visionary pointing the direction for us. 

Margaret (Peg) Cushman, Professor of Nursing and former President of the Visiting Nurses Association

Although Val has chosen to stay in the background, he deserves much of the credit for what was accomplished both at the U.S. Senate Special Committee on Aging, where he was closely associated with me and at the House Select Committee on Aging, where he was Congressman Claude Pepper’s senior counsel and closest advisor. He put together more hearings on the subject of aging, wrote more reports, drafted more bills, and had more influence on the direction of events than anyone before him or since.

Frank E. Moss, former U.S. Senator

Val’s most important contribution is pulling together all elements of home health care and being able to organize and energize the people involved in the industry.

Frank E. Moss, former U.S. Senator

Anyone working on health care issues in Congress knows the name Val J. Halamandaris.

Kathleen Gardner Cravedi, former Staff Director of the House Select Committee on Aging

Without your untiring support and active participation, the voices of people advocating meaningful and compassionate health care reform may not have been heard by national leaders.

Michael Sullivan, Former Executive Director, Indiana Association for Home Care

All of us have been members of many organizations and NAHC is simply the best there is. NAHC aspires to excellence in every respect; its staff has been repeatedly honored as the best in Washington; the organization lives by the highest values and has demonstrated a passionate interest in the well-being of patients and providers.

Elaine Stephens, Director of Home Care of Steward Home Care/Steward Health Systems and former NAHC C

Home care increasingly is one of the basic building blocks in the developing system of long-term care.  On both economic and recuperative bases, home health care will continue to grow as an essential service for individuals, for families and for the community as a whole.

Former U.S. Senator Olympia Snowe (R-ME)

NCOA is excited to be part of this great event and honored to have such influential award winners in the field of aging.

National Council of Aging

Health care at home…is something we need more of, not less of.  Let us make a commitment to preventive and long-term care.  Let us encourage home care as an alternative to nursing homes and give folks a little help to have their parents there.

Former President Bill Clinton

NAHC Addresses RAP Suppression with Palmetto GBA

April 29, 2013 04:46 PM

Palmetto GBA, the largest home health and hospice Medicare Administrative Contractor (MAC) took steps last week to suppress payments to home health agencies identified as having a “high number” of auto-cancelled Requests for Anticipated Payment (RAP). At this time, Palmetto plans to suppress RAP payments for any home health agency that had 100 or more RAPs auto-cancelled between January 1 and April 15, 2013 (See NAHC Report, April 23, 2013).

In response to calls for assistance from its members, the National Association for Home Care and Hospice (NAHC) contacted Palmetto to discuss this action and identify steps home health agencies should take to be removed from RAP suppression. NAHC pointed out that Medicare’s authority to suppress RAP payments is based on program integrity, and therefore RAP payment suppression should be limited to cases where fraud or abuse is suspected. NAHC suggested that Palmetto carry out a second level of information analysis before suppressing RAP payments based simply a number of cancelled RAPs in order to ensure that only agencies that are suspected of fraudulent or abusive practices are having their payments suppressed.

On its website, Palmetto identified steps that home health agencies should take to have their RAP payment suppression lifted. This includes submission of a Corrective Action Plan to Palmetto as follows:

When submitting the Corrective Action Plan, it should include a statement of the problem or weakness that caused the delay in filing final claims, include proposed solutions to the problem, and state who is responsible for the monitoring the CAP. Palmetto GBA will review each CAP on a case-by-case basis depending on the provider-specific circumstances. If an agency believes they were timely in filing final claims, or has a rationale for the number of cancelled RAPs, they can send a rebuttal to the fax number listed in the letter (803-462-2659). In the rebuttal they can identify the reason(s) the RAPs cancelled and the number of RAPs affected. Any salient information is useful.  

According to a representative, Palmetto will review all Corrective Action Plans promptly and send recommendations to the Centers for Medicare & Medicaid Services (CMS) for final approval or rejection.

During correspondence with Palmetto, NAHC pressed for consideration of any legitimate reasons an agency has for a large number of auto-cancelled RAPs – such as unsuccessful efforts to get orders/F2F signed, temporary staffing problem during the first quarter, new software or software problems. NAHC emphasized that immediate removal from RAP suppression should be considered for agencies where 100 auto-cancelled RAPs represent a small percentage of paid claims.  NAHC also recommended that an edit be based on the percentage of auto-cancelled RAPs - the greater of 25 auto-cancelled RAPs in a month or 25% of total RAPs in the period - for consideration.

NAHC further suggested that any agency that can provide an acceptable explanation for failure to submit final claims should have immediate removal from RAP suppression. Finally, NAHC recommended the timeline for evaluation of successful implementation of an agency corrective action plan be carried out in no more than one month, rather than three months as stated in the letters.

In review of reasons offered by NAHC for high numbers of auto-cancelled RAPs, Palmetto did raise an objection to unsuccessful efforts to secure physician signatures alone as acceptable, pointing out that all agencies must comply with this requirement. However, any reasonable explanation submitted with a Corrective Action Plan will be considered if accompanied by supporting evidence.

Palmetto acknowledged that they will consider adopting refinements to the RAP suppression project in future months, with agency size as a definite consideration. Palmetto also admitted that they are still refining efforts to look for final claims. In response to a NAHC request to provide pre-suppression opportunities to submit an explanation for the volume of auto-cancelled RAPs, Palmetto pointed to the warning letters that are being sent to agencies with 50-99 auto-cancelled RAPS as a step in that direction. The organization also responded to NAHC’s recommendation for evaluating the restoration of RAP privileges on a monthly basis, saying that they will evaluate agencies’ performance as they go along, and if there is legitimate improvement will recommend removing RAP suppression short of 3 months.

Home Health Agency Responses

Home health agencies must first determine whether Palmetto’s findings are correct, and rebut if incorrect.  Agencies that have a high number of auto-cancelled RAPs should develop a plan of correction that includes documented evidence of reasons why they were unable to submit final claims timely.  Also, if the majority of their auto-cancelled RAP episodes eventually result in a final claim payment, this data should be included. Large agencies should include evidence that the percent of RAPS being auto-cancelled is small and that suppression of RAP payment is unjustified in their case. The analysis of cause - with supporting evidence - and corrective action plans should be sent by fax to Palmetto as soon as possible. Finally, evidence of financial hardship resulting from RAP payment suppression should be included.

NAHC also recommends that home health agencies monitor their outstanding RAPS and, if they believe they will be unable to submit the final claim before the 120 days, they should cancel those RAPs before they are auto-cancelled.




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