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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 Provides Recommendations for Complying with New Face-to-Face Rules

January 26, 2015 10:52 AM

In the final rule for the 2015 home health prospective payment rate update, the Centers for Medicare & Medicaid Services (CMS) revised the face-to-face (F2F) encounter requirements for physician certification for home health services. In the rule, CMS eliminated the narrative requirement, which required the certifying physician to provide a detailed explanation on why the patient was homebound and in need of skilled services. CMS will still require that the face-to-face encounter occurred no more than 90 days prior to the home health start of care date or within 30 days of the start of the home health care, be related to the primary reason the patient is receiving home health services, and be performed by a physician or allowed non-physician practitioner (NPP).

In addition to eliminating the narrative requirement, CMS has also altered its medical review process for determining patient eligibility for home health services. Not only will CMS request the agency’s medical record when additional documentation is requested, they will also be looking for evidence that supports eligibility for home health services from the physician’s medical record.  

CMS will require that the home health agency submit pertinent sections of the certifying physician’s medical record when an agency’s claim is requested for review. If the documentation in the physician’s record is insufficient to support eligibility, the home health agency’s claim will be denied. According to CMS:

“In determining whether the patient is or was eligible to receive services under the Medicare home health benefit at the start of care, we will require documentation in the certifying physician’s medical records and/or the acute/post-acute care facility’s medical records (if the patient was directly admitted to home health) to be used as the basis for certification of home health eligibility.

We will require the documentation to be provided upon request to the home health agency, review entities, and/or CMS. Criteria for patient eligibility are described at § 424.22(a)(1) and § 424.22(b). HHAs should obtain as much documentation from the certifying physician’s medical records and/or the acute/post-acute care facility’s medical records (if the patient was directly admitted to home health) as they deem necessary to assure themselves that the Medicare home health patient eligibility criteria have been met and must be able to provide it to CMS and its review entities upon request.”

CMS will permit the agency to inform the certifying physician of the agency’s findings from their comprehensive assessment that supports the patient’s eligibility for home health care. The certifying physician will need to sign the additional information and incorporate it into his/her medical record. States CMS:

“It is permissible for the HHA to communicate with and provide information to the certifying physician about the patient’s homebound status and need for skilled care and for the certifying physician to incorporate this information into his or her medical record for the patient. The certifying physician must review and sign off on anything incorporated into his or her medical record for the patient that is used to support his/her certification/recertification of patient eligibility for the home health benefit.

In addition, any information from the HHA (including the comprehensive assessment) that is incorporated into the certifying physician’s and/or the acute/post-acute care facility’s medical record for the patient (if the patient was directly admitted to home health) and used to support the certification of patient eligibility for the home health benefit, must corroborate the certifying physician’s and/or the acute/post-acute care facility’s own documentation/ medical record entries...”

CMS explained that it is eliminating the narrative requirement “to simplify the face-to-face encounter regulations, reduce burdens for HHAs and physicians, and to mitigate instances where physicians and HHAs unintentionally fail to comply with certification requirements.”However, CMS’ revisions seem to have made the F2F requirements even more burdensome.  In addition, the only guidance CMS has provided thus far has been through a National Provider call held in late December 2014.

During the call, CMS reiterated the regulatory requirements and provided some examples of appropriate physician F2F encounter notes and discharge summaries along with a note that did not adequately address reasons for homebound and/or skilled services. When the encounter documentation is insufficient, CMS maintains that agencies would be permitted to fill in the “gaps” by supplying the physician with information from the agency’s assessment that supports eligibility. They also stated that the agency could add the information to the plan of care (POC) that is sent to physician for review and signature.

CMS failed, however, to address how agencies are expected to operationalize many other aspects of the new requirement, particularly as they relate to patients who have a F2F encounter conducted by a physician from an acute/post acute care facility. Further, there has been no indication of what the Medicare medical review contractors will be looking for in the physician’s record that substantiates eligibility.

In December, the National Association for Home Care & Hospice (NAHC) sent a letter to the Administrator of CMS requesting a phased–in approach to implementation of the new F2F requirements. Since then, NAHC has made multiple attempts to get answers from CMS.  Only recently did a CMS official contact NAHC. They indicated that they were in serious discussions within CMS to develop an appropriate approach for implementation; however, nothing is concrete at this time.

So what are agencies to do in the meantime? Based on information NAHC has gathered thus far, the organization offers the following recommendations:

  • Agencies should submit to the certifying physician a summary of the clinical finding from their assessment that supports the need for skilled services and reason for homebound. Include the pertinent sections of the comprehensive assessment and the OASIS to substantiate the findings.
  • Include a statement at the end of the summary that will serve as an attestation that the physician agrees with the summary and is incorporating the information into his/her medical record.
  • Request that the physician sign and date the document and return it to the agency
  • Both the summary and attestation statement can be included on the POC that is sent to the physician. However, keep in mind that the elements required on a home health POC alone do not provide adequate information to support eligibility for home health services. 
  • CMS will look at the physician’s medical record in determining that the certification requirements have been met, therefore, the physician should also keep a copy of any document that contains the certification statement.
  • CMS will review the physician’s encounter note/discharge summary for the date of the encounter, confirm that the encounter is related to the primary reason for home health service, and that the encounter was conducted by the physician or an allowed NPP.
    If the documentation on the encounter note is insufficient to support eligibility, CMS   will look to other documents or evidence in the physician’s record to support home health eligibility. Therefore, it is very important that the agency supply the physician with any information that supports eligibility so that it may be incorporated into the physician’s record as soon as possible.
  • CMS will not require that the agency obtain the physician’s medical record prior to billing. However, agencies will still need to be assured that F2F encounter occurred as part of the certification prior to billing.  Agencies can accomplish this in several ways:
    • Agencies may continue to use the F2F encounter document form, or a modified form, that has been in place since the beginning of the F2F encounter requirement. Continuing to use the form will provide the agency with tangible evidence that a F2F encounter had been conducted. However, CMS will look for the actual visit note /discharge summary that the information is based on.  
    • The agency could include a statement on the POC or documentation that is sent to the physician that serve as an attestation that a F2F encounter was conducted within the required time frame, the encounter was related to the primary reason for home health services, and the encounter was conducted by the physician or am allowed NPP.
    • Request the actual note from the physician
  • Agencies should still obtain as much information from the physician as soon as possible,  

There are still many unanswered questions regarding how agencies are to adequately comply with the new F2F rules. NAHC, along with others, have many outstanding questions that have been submitted to CMS.  We will continue to work with CMS to arrive at a reasonable resolution. Look for future NAHC report articles as we learn more.




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