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Testimonials

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. 

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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.

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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

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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 element...it’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

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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.

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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.

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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.

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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.

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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.

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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.

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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. 

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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.

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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.

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Frank E. Moss, former U.S. Senator

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

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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.

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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.

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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.

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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.

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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.

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Former President Bill Clinton

Rule for Emergency Preparedness Proposes Significant Expansion of Home Health, Hospice Duties

CMS seeks input on timing, other aspects of comprehensive rule
March 18, 2014 03:31 PM

As reported previously in NAHC Report from January 8, 2014, in late December 2013 the Centers for Medicare & Medicaid Services (CMS) proposed a comprehensive set of emergency preparedness requirements affecting 17 different Medicare and Medicaid-participating provider types - including hospice and home health.  Subsequently, CMS extended the comment period for the regulations until March 31, 2014.

The proposed Conditions of Participation (CoP) and Conditions for Payment (CfP) were developed from a core set of requirements aimed at inpatient hospitals that were modified to address various other provider types (taking into consideration the populations they serve).  All designated provider and supplier types will be required to meet the following general requirements:

  • Risk assessment and planning (including establishment of an emergency preparedness program and development of an emergency plan that is subject to annual review and updating)
  • Policies and procedures (development and implementation of emergency preparedness policies and procedures based on the emergency plan that should be reviewed and updated on an annual basis)
  • Communications plan  (development and maintenance of an emergency preparedness communication plan meeting federal and state law and that is reviewed and updated annually) and
  • Training and testing (carrying out of initial training in emergency preparedness policies and procedures and thereafter on an annual basis; ensuring that staff are able to demonstrate knowledge of emergency procedures; conducting of exercises to test the emergency plan)

To view the proposed rule and information on how to submit comments, click here

The existing CoP for home health do not contain an emergency preparedness requirement; neither do the hospice CoP applicable to hospices without inpatient facilities.  The proposed hospice-specific requirements would delete paragraph 418.110(c)(1)(ii) from the existing hospice CoP under the inpatient “safety management” section including a general requirement that the hospice have an emergency preparedness plan that must periodically be reviewed and rehearsed and replace it with more explicit requirements (see table below).

The National Association for Home Care & Hospice (NAHC) and its affiliated Hospice Association of America (HAA) have significant concerns regarding CMS’ estimates of added provider cost burdens resulting from these proposed regulations and urge providers to assess whether CMS’ estimates are representative of the actual costs that providers will incur in implementing the proposed regulations.  Additionally, and equally important, are NAHC’s concerns that CMS provides only limited relief from regulatory burdens during time of emergency.  Under Section 1135 of the Social Security Act, the Secretary of Health and Human Services may waive certain requirements (such as those related to the CoP) in order to ensure that individuals are able to access needed health care services. 

NAHC believes that CMS should conduct (or seek legislative authority to conduct) a comprehensive review of all regulatory requirements and  develop a more comprehensive list of regulatory requirements that it can reasonably waive under different types of emergencies, and establish a process for implementing those waivers.  NAHC encourages providers to include this recommendation in comments on the proposed emergency preparedness regulations, and, if possible cite specific requirements that could/should be waived during emergencies.

CMS is requesting specific feedback on a number of different issues as part of this proposed regulation, including:

  • PROCESS FOR IMPLEMENTATION:  CMS is soliciting comments on whether certain requirements should be implemented on a staggered basis.
  • TIMING OF IMPLEMENTATION:  CMS is seeking public comments on when these CoPs should be implemented.
  • SUBSISTENCE NEEDS:  Specifically, with respect the proposed requirement that hospitals, CAHs, inpatient hospice facilities, PRTFs, LTC facilities, ICFs/IID, and RNHCIs would be required to maintain various subsistence needs, CMS is requesting public comment as to whether this should be a requirement and in what quantities and for what time period these subsistence needs would be maintained.  CMS notes that the proposed rule addresses subsistence needs for staff and patients, but is, additionally, requesting comment on whether facilities should be required to maintain an extra store of provisions to address the needs of volunteers, visitors, and individuals from the community that could offer assistance or seek shelter.
  • TIMING FOR UPDATES OF POLICIES AND PROCEDURES:  As part of the proposed rule, CMS would require policies and procedures related to the emergency preparedness policies and procedures, risk assessment, and communication plan be reviewed and updated at least annually.  CMS is seeking public comment on the timing of the update.
  • Request for Comments on Alternative Approaches to ImplementatioN:  CMS is seeking comment on the advisability of the following approaches, as well:
    • Targeted approaches to emergency preparedness—covering one or a subset of provider classes to learn from implementation prior to extending the rule to all groups.
    • A phase in approach—implementing the requirements over a longer time horizon, or differential time horizons for the respective provider classes. CMS is proposing to implement all of the requirements 1 year after the final rule is published.
    • Variations of the primary requirements—for example, CMS has proposed requiring two annual training exercises—it would be instructive to receive public feedback on whether both should be required annually, semiannually, or if training should be an annual or semiannual requirement.
    • Integration with current requirements—CMS is soliciting comment on how the proposed requirements will be integrated with/ satisfied by existing policies and procedures which regulated entities may have already adopted.
  • COMMENTS ON PROVIDER BURDEN: Under the Paperwork Reduction Act of 1995, CMS must seek public comment on the following issues, as well, so is seeking comment on each of the following issues:
    • The need for the information collection and its usefulness in carrying out the proper functions of our agency.
    • The accuracy of our estimate of the information collection burden.
    • The quality, utility, and clarity of the information to be collected.
    • Recommendations to minimize the information collection burden on the affected public, including automated collection techniques.

Below is a table comparing the proposed new CoP for Hospice and Home Health providers. NAHC will be developing comments for submission to CMS; if home health or hospice providers would like their comments to be considered for inclusion in NAHC’s comments, please email them by COB Wednesday, March 19, to the following:

HOME HEALTH:  Mary Carr (mkc@nahc.org)

HOSPICE:  Theresa Forster (tmf@nahc.org) or Katie Wehri (Katie@nahc.org)

                                                           

HOSPICE

HOME HEALTH SERVICES

Amend §418.110 by removing paragraph (c)(1)(ii)

[Text for(c)(1)(ii):  (ii) The hospice must have a written disaster preparedness plan in effect for managing the consequences of power failures, natural disasters, and other emergencies that would affect the hospice's ability to provide care. The plan must be periodically reviewed and rehearsed with staff (including non-employee staff) with special emphasis placed on carrying out the procedures necessary to protect patients and others.]

 

§ 418.113 Condition of Participation: Emergency preparedness.

The hospice must comply with all applicable Federal and State emergency preparedness requirements. The hospice must establish and maintain an emergency preparedness program that meets the requirements of this section. The emergency preparedness program must include, but not be limited to, the following elements:

Add § 484.22 to subpart B to read as follows:

§ 484.22 Condition of participation: Emergency preparedness.

The Home Health Agency (HHA) must comply with all applicable Federal and State emergency preparedness requirements. The HHA must establish and maintain an emergency preparedness program that meets the requirements of this section. The emergency preparedness

program must include, but not be limited to, the following elements:

(a) Emergency plan.The hospice must develop and maintain an emergency preparedness plan that must be reviewed, and updated at least annually.

The plan must do the following:

(1)  Be based on and include a documented, facility-based and community -based risk assessment, utilizing an all-hazards approach.

(2)  Include strategies for addressing emergency events identified by the risk assessment, including the management of the consequences of power failures, natural disasters, and other emergencies that would affect the hospice’s ability to provide care.

(3)  Address patient population, including, but not limited to, the type of services the hospice has the ability to provide in an emergency; and continuity of operations, including delegations of authority and succession plans.

(4)  Include a process for ensuring cooperation and collaboration with local, tribal, regional, State, or Federal emergency preparedness officials’ efforts to ensure an integrated response during a disaster or emergency situation, including documentation of the hospice’s efforts to contact such officials and, when applicable, of its participation in collaborative and cooperative planning efforts.

(a) Emergency plan.The HHA must develop and maintain an emergency preparedness plan that must be reviewed, and updated at least annually.

The plan must:

(1)  Be based on and include a documented, facility-based and community-based risk assessment, utilizing an all-hazards approach;

(2)  Include strategies for addressing emergency events identified by the risk assessment;

(3)  Address patient population, including, but not limited to, the type of services the HHA has the ability to provide in an emergency; and continuity of operations, including delegations of authority and succession plans.

(4)  Include a process for ensuring cooperation and collaboration with local, tribal, regional, State, and Federal emergency preparedness officials’ efforts to ensure an integrated response during a disaster or emergency situation, including documentation of the HHA’s efforts to contact such officials and, when applicable, of its participation in collaborative and cooperative planning efforts.

(b) Policies and procedures.The hospice must develop and implement emergency preparedness policies and procedures, based on the emergency plan set forth in paragraph (a) of this section, risk assessment at paragraph (a)(1) of this section, and the communication plan at paragraph (c) of this section. The policies and procedures must be reviewed and updated at least annually. At a minimum, the policies and procedures must address the following:

(1)  A system to track the location of hospice employees and patients in the hospice’s care both during and after the emergency.

(2)  Procedures to inform State and local officials about hospice patients in need of evacuation from their residences at any time due to an emergency situation based on the patient’s medical and psychiatric condition and home environment.

(3)  A system of medical documentation that preserves patient information, protects confidentiality of patient information, and ensures records are secure and readily available.

(4)  The use of hospice employees in an emergency and other emergency staffing strategies, including the process and role for integration of State and Federally designated health care professionals to address surge needs during an emergency.

(5)  The development of arrangements with other hospices and other providers to receive patients in the event of limitations or cessation of operations to ensure the continuity of services to hospice patients.

(6)  The following are additional requirements for hospice-operated inpatient care facilities only. The policies and procedures must address the following:

(i)A means to shelter in place for patients, hospice employees who remain in the hospice.

(ii)  Safe evacuation from the hospice, which includes consideration of care and treatment needs of evacuees; staff responsibilities; transportation; identification of evacuation location(s), and primary and alternate means of communication with external sources of assistance.

(iii) The provision of subsistence needs for hospice employees and patients, whether they evacuate or shelter in place, include, but are not limited to the following:

(A) Food, water, and medical supplies.

(B) Alternate sources of energy to maintain the following:

(1) Temperatures to protect patient health and safety and for the safe and sanitary storage of provisions.

(2) Emergency lighting.

(3) Fire detection, extinguishing, and alarm systems.

             (C) Sewage and waste disposal.

(iv) The role of the hospice under a waiver declared by the Secretary, in accordance with section 1135 of the Act, in the provision of care and treatment at an alternate care site identified by emergency management officials.

(b) Policies and procedures.The HHA must develop and implement emergency preparedness policies and

procedures, based on the emergency plan set forth in paragraph (a) of this section, risk assessment at paragraph

(a)(1) of this section, and the communication plan at paragraph (c) of this section. The policies and procedures must be reviewed and updated at least annually. At a

minimum, the policies and procedures must address the following:

(1)  The plans for the HHA’s patients during a natural or man-made disaster. Individual plans for each patient must be included as part of the comprehensive patient assessment, which must be conducted according to the provisions at § 484.55.

(2)  The procedures to inform State and local emergency preparedness officials about HHA patients in need of evacuation from their residences at any time due to an emergency situation based on the patient’s medical and psychiatric condition and home environment.

(3)  A system to track the location of staff and patients in the HHA’s care both during and after the emergency.

(4)  A system of medical documentation that preserves patient information, protects confidentiality of patient information, and ensures records are secure and readily available.

(5)  The use of volunteers in an emergency or other emergency staffing strategies, including the process and role for integration of State or Federally designated health care professionals to address surge needs during an emergency.

(6)  The development of arrangements with other HHAs or other providers to receive patients in the event of limitations or cessation of operations to ensure the continuity of services to HHA patients.

(c) Communication plan.The hospice must develop and maintain an emergency preparedness communication plan that complies with both Federal and State law and must be reviewed and updated at least annually. The communication plan must include all of the following:

(1) Names and contact information for the following:

(i) Hospice employees.

(ii) Entities providing services under arrangement.

(iii) Patients’ physicians.

(iv) Other hospices.

(2) Contact information for the following:

(i) Federal, State, tribal, regional, and local emergency preparedness staff.

(ii) Other sources of assistance.

(3) Primary and alternate means for communicating with the following:

(i) Hospice’s employees.

(ii) Federal, State, tribal, regional, and local emergency management agencies.

(4) A method for sharing information and medical documentation for patients under the hospice’s care, as necessary, with other health care providers to ensure continuity of care.

(5) A means, in the event of an evacuation, to release patient information as permitted under 45 CFR 164.510.

(6) A means of providing information about the general condition and location of patients under the facility’s care as permitted under 45 CFR 164.510(b)(4).

(7) A means of providing information about the hospice’s inpatient occupancy, needs, and its ability to provide assistance, to the authority having jurisdiction, the Incident Command Center, or designee.

(c) Communication plan.The HHA must develop and maintain an emergency preparedness communication plan that complies with both Federal and State law and must be reviewed and updated at least annually. The communication plan must include all of the following:

(1) Names and contact information for the following:

(i) Staff.

(ii) Entities providing services under arrangement.

(iii) Patients’ physicians.

(iv) Other HHAs.

(v) Volunteers.

(2) Contact information for the following:

(i) Federal, State, tribal, regional, or local emergency preparedness staff.

(ii) Other sources of assistance.

(3) Primary and alternate means for communicating with the HHA’s staff, Federal, State, tribal, regional, and local emergency management agencies.

(4) A method for sharing information and medical documentation for patients under the HHA’s care, as necessary, with other health care providers to ensure continuity of care.

(5) A means of providing information about the general condition and location of patients under the facility’s care as permitted under 45 CFR 164.510(b)(4).

(6) A means of providing information about the HHA’s needs, and its ability to provide assistance, to the authority having jurisdiction, the Incident Command Center, or designee.

(d) Training and testing.The hospice must develop and maintain an emergency preparedness training and testing program that must be reviewed and updated at least annually.

(1) Training program.The hospice must do all of the following:

(i) Initial training in emergency preparedness policies and procedures to all new and existing hospice employees, and individuals providing services under arrangement, consistent with their expected roles.

(ii) Ensure that hospice employees can demonstrate knowledge of emergency procedures.

(iii) Provide emergency preparedness training at least annually.

(iv) Periodically review and rehearse its emergency preparedness plan with hospice employees (including nonemployee staff), with special emphasis placed on carrying out the procedures necessary to protect patients and others.

(v) Maintain documentation of all emergency preparedness training.

(2) Testing.The hospice must conduct exercises to test the emergency plan. The hospice must do the following:

(i) Participate in a community mock disaster drill at least annually. If a community mock disaster drill is not available, conduct an individual, facility-based mock disaster drill at least annually.

(ii) If the hospice experiences an actual natural or man-made emergency that requires activation of the emergency plan, the hospice is exempt from engaging in a community or individual, facility-based mock disaster drill for 1 year following the onset of the actual event.

(iii) Conduct a paper-based, tabletop exercise at least annually. A tabletop exercise is a group discussion led by a facilitator, using a narrated, clinically relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan.

(iv) Analyze the hospice’s response to and maintain documentation of all drills, tabletop exercises, and emergency events, and revise the hospice’s emergency plan, as needed.

(d) Training and testing.The HHA must develop and maintain an emergency preparedness training and testing program that must be reviewed and updated at least annually.

(1)Training program. The HHA must do all of the following:

(i) Initial training in emergency preparedness policies and procedures to all new and existing staff, individuals providing services under arrangement, and volunteers, consistent with their expected roles.

(ii) Provide emergency preparedness training at least annually.

(iii) Maintain documentation of the training.

(iv) Ensure that staff can demonstrate knowledge of emergency procedures.

(2) Testing.The HHA must conduct drills and exercises to test the emergency plan. The HHA must do the following:

(i) Participate in a community mock disaster drill at least annually. If a community mock disaster drill is not available, conduct an individual, facility-based mock disaster drill at least annually.

(ii) If the HHA experiences an actual natural or man-made emergency that requires activation of the emergency plan, the HHA is exempt from engaging in a community or individual, facility based mock disaster drill for 1 year following the onset of the actual event.

(iii) Conduct a paper-based, tabletop exercise at least annually. A tabletop exercise is a group discussion led by a facilitator, using a narrated, clinically relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan.

(iv) Analyze the HHA’s response to and maintain documentation of all drills, tabletop exercises, and emergency events, and revise the HHA’s emergency plan, as needed.

 

 

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