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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

Heath 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

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

CMS Proposes Revisions to Provider Enrollment Requirements

June 6, 2013 10:49 AM

In an April 2013 notice of proposed rulemaking (NPR) the Centers for Medicare & Medicaid Services (CMS) made known its plans to add new requirements to provider enrollment and expansion of CMS authority to revoke Medicare billing privileges.  This NPR also proposes revisions to the Incentive Reward Program by increasing the reward amounts to individuals who report information leading to identification of fraudulent activity.

Incentive Reward Program

As required by the Health Insurance Portability and Accountability Act (HIPAA), CMS established a program for encouraging the reporting of information about individuals or entities engaging in acts that serve as grounds for the imposition of sanctions or engage in Medicare or Medicaid fraud. In this notice, CMS proposes to increase the potential reward in order to motivate more individuals to review their Medicare Summary Notice and report suspicious activity. Criteria under which CMS will issue rewards, plans to limit rewards to the first individual who provides information, new attestation requirements, and notification of eligibility are addressed.

Expanded Provider Enrollment and Revocation 

Further, changes to enrollment requirements and additional basis for revocation or billing privileges have been proposed. A minor informational change is proposed to the definition of Medicare enrollment to include enrollment via the 855-O of those individuals who wish solely to order and refer Medicare for services.  However, several other changes to enrollment limitations and the deactivation of billing privileges have been proposed. These proposals must be carefully analyzed in order to determine their impact on new and existing home health and hospice providers.

Below is a brief summary of these proposed changes:

  • Expands denial of enrollment to any provider, supplier, or current owner that was the owner of a prior provider or supplier that had a Medicare debt (changed from overpayment) when that other provider’s enrollment was terminated – either voluntarily or involuntarily - if:
    • The owner left within one year of the termination
    • The debt has not been fully repaid or an extended repayment plan has not approved
    • CMS determines that the debt poses an undue risk of fraud, waste or abuse
  • Expands denial of enrollment or revocation of Medicare billing privileges to include managing employees if the provider, supplier, owner or managing employee was convicted of a felony within the past 10 years. Managing employees would be inclusive of corporate officers and directors and/or board of directors.
  • Expands revocation to include findings that a provider is no longer operational or otherwise fails to satisfy any Medicare enrollment requirements.
  • Expands prohibitions to include any felony conviction within the preceding 10 years rather than a defined list of felonies, including guilty pleas and adjudicated pretrial diversions that are determined to be detrimental to the best interests of the Medicare program.
  • Adds felony convictions of managing employees.
  • Expands revocation of Medicare billing privileges if the provider or supplier has a pattern or practice of billing for services that do not meet Medicare requirements, such as services that were not reasonable or necessary, a pattern of inaccurate or erroneous claim submissions, or where a beneficiary is deceased.
  • Requires all revoked providers and suppliers to submit remaining claims within 60 days after their revocation except home health agencies which must submit claims within 60 days of the date that the last home health agency episode ends or 60 days after revocation, whichever is later.
  • Specifies that all re-enrollment bars begin 30 days after CMS or its contractors mail notice of the revocation determination except for failure to revalidate, to which the enrollment bar does not apply.

Corrective Action Plan Limitations

CMS also plans to amend 405.809 to allow providers the ability to submit a corrective action plan (CAP) to violations of 424.535(a)(1) but to limit them to one opportunity to correct all of the deficiencies that served as the basis for a revocation.

CMS proposed this change to ensure that provider that only minimally failed o comply with enrollment requirements can quickly and easily be corrected. A CAP should not be available if a provider is revoked based on an OGI exclusion or felony conviction of false or misleading information, or failure to change practice locations. In these cases a formal appeal would be required.

Considerations for Comments

The proposed rule raises a number of concerns due to the unlimited and ill-defined authority it affords CMS. For example, the new requirement on prior debt, which will require reporting affiliation with previous providers, fails to address consideration of outstanding Medicare appeals of prior debts.

Further, although CMS identifies the amount of debt, length of timeframe an individual was an owner, and the percentage of ownership as considerations in its analysis for denying enrollment, it does not establish measurable targets for decision making. CMS has solicited comments on the considerations it has identified and seeking suggestions of others that should be included for enrollment of owners with prior debt to the Medicare program.

CMS is also soliciting comments on its proposal to expand the revocation of Medicare billing privileges if a provider or supplier has a pattern or practice of billing for services that do not meet Medicare requirements, and/or a pattern of inaccurate claims submission. CMS intends to “focus on submission of numerous or abnormally high volume of claims denied over time…” CMS is seeking comments on its plan to include such things factors as: the percentage of submitted claims denied, total number of claims denied, the reason for denial, history of final adverse actions, the length of time over which the pattern continued and how long the provider has been enrolled. 

CMS is also looking for recommendations for additional factors to consider, what not to consider, whether greater or lesser weight should be applied to factors, a minimum or maximum threshold for percentage of claims denied, a  total number denied, and knowledge standard (i.e. reckless disregard versus knew or should have known).

Serious consideration must be given to this proposal in light of problems providers have experienced with medical review decisions by the various contractors. Also, the proposal fails to address how denials that are overturned upon appeal will be factored.

CMS did not request comments on its proposals to expand felonies to “any that have been determined to be detrimental to the Medicare program.” However, providers should be prepared to weigh in on whether a bright line test should be in place for making this determination, rather than leaving this decision totally in the hands of CMS.

The public is invited to comment on the proposed rule. Comments must be submitted by 5:00pm EST on June 28, 2013.

Instructions for submission of comments can be found in the Federal Register notice here.




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