Skip to Main Content
National Association for Home Care & Hospice
Twitter Facebook Pintrest


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

Status Update and CALL FOR INPUT! HOSPICE NOE/NOTR Timely Filing Requirements

August 30, 2015 12:19 PM

Since the October 2015 implementation of the timely filing requirements for the Notice of Election (NOE) and Notice of Election Termination/Revocation (NOTR), hospice providers have encountered significant difficulties in ensuring timely processing of the notices, resulting in lost revenues and increased administrative costs. The National Association for Home Care & Hospice (NAHC) and the National Hospice and Palliative Care Organization (NHPCO) are conducting a joint survey designed to gather information from hospice providers about challenges they have encountered as they work to meet the new filing requirements. The information gathered in the survey will be used in communications with the Centers for Medicare & Medicaid Services (CMS) and others in our efforts to address ongoing NOE/NOTR processing concerns.

A SPECIAL NOTE ABOUT THE NAHC/NHPCO SURVEY: The information sought in the survey is vital to our advocacy efforts, but the survey is lengthy and requests some specific data from hospice providers. To simplify the survey response process for hospice providers, we make the following recommendations:

  • Review the survey prior to filling it out online. We are providing a link to a “survey worksheet” that hospices can download, print, review, and make notations on prior to going to the live survey link to key and submit data.
  • If you are a hospice with more than one provider number, make a decision as to whether you will submit your experience as a single submission or if each program will submit separately.
  • We recognize that the survey is lengthy and hospice providers are busy. If you can’t complete the entire survey, please supply as many answers as you can.
  • If there is not sufficient space in the survey to supply all of the information you would like about particular issues you have run into with the NOE/NOTR filing requirements, feel free to email NAHC staff at or with any additional comments you may have.
  • Please note that Section IV has 3 required response questions (questions 1, 4, and 5) that require numeric responses. There are specific warnings that display in red if the response is not numeric.
  • THANK you for participating!

Background: The NOE alerts the Medicare Administrative Contractor (MAC) and the Common Working File (CWF) that a patient has elected the hospice benefit. The NOTR alerts the MAC and the CWF that a patient either has revoked the hospice benefit or has been discharged live from hospice care.  Accurate representation of a patient’s hospice status in the CWF will help reduce the amount of inappropriate billings outside of hospice for items and services for treatment of a patient’s principal terminal condition and other conditions that contribute to the hospice prognosis.

Timely Filing: During 2014, CMS imposed a “timeliness” standard for submission of NOEs and NOTRs to help ensure that the CWF reflects a patient’s status relative to his/her hospice election as soon as possible. Effective for dates of service beginning on or after Oct. 1, 2014, hospices must submit the NOE and have the NOE “accepted” by the MAC within 5 calendar days following the hospice admission.  NOEs can only be submitted via direct data entry (DDE) using the Fiscal Intermediary Standard System (FISS), or via a paper UB-04; they cannot be submitted electronically. To be “accepted” by the MAC, the NOE must be free of billing or keying errors that would cause the NOE to be returned or rejected. If a NOE has not been submitted/accepted timely, the hospice is not eligible to receive payment for the days of care occurring prior to MAC acceptance of a valid NOE. Further, if a NOE has been accepted but includes information that was incorrect at the time of submission, the hospice must cancel the notice and resubmit. Cancellation and resubmission of an NOE invalidates the acceptance of any previous NOE and the hospice will not be paid for all days of care prior to system acceptance of the second NOE.

Effective for live discharges or revocations occurring on or after October 1, 2014, hospices must submit the NOTR and have the NOTR accepted by the MAC within the 5 calendar days following the discharge/revocation unless a final claim has already been submitted. Most hospices cannot submit final bills within the 5-day window because they are awaiting billings for prescription medications and other items that must be included on a final bill. NOTRs must be submitted to the MAC via direct data entry (DDE) into FISS. As mentioned above relative to the NOE, if a NOTR has been accepted by the MAC but includes information that was incorrect at the time of submission, the hospice must cancel the notice and resubmit.

Concerns: NAHC has heard from numerous hospice providers regarding problems that have arisen as the result of the timely filing requirement for NOEs/NOTRs. These include:

  • Since both the NOE and the NOTR must be submitted via DDE, all information on the form must be keyed directly into the FISS system. Direct data entry is subject to human error, and a single keystroke can invalidate a notice and have serious financial consequences.
  • The timeframes for feedback on where the notice is in processing and whether the notice has been accepted by the MAC vary widely depending on the number of system “edits” the form must process through. At times hospices do not know that a notice is being rejected (or “returned to provider”--RTP’d) due to an error or conflict with data in CMS’ systems until after the 5 day “timely” window has passed. Once the RTP is received, the hospice must resubmit the NOE; under such circumstances it is almost guaranteed that the hospice will lose payment for several days of care that has been provided.
  • If a hospice identifies an error following submission of the NOE but while the notice is still processing, and the error is one that would be picked up by edits in the FISS or CWF systems, the hospice may resubmit the NOE before processing is finalized. Under the limited circumstances where a keying error would be caught by systems edits and result in the notice being RTP’d, this may help providers to avoid the penalty associated with late filing. However, the data associated with many information fields on the NOE would not be caught by systems edits, and hospice providers have no way of correcting these data elements prior to the notice being processed by the system and RTP’d. In essentially all cases where data cannot be corrected by the hospice due to systems limitations, the provider must wait for the notice to process and reject, after which a new notice must be submitted for processing. In virtually all such cases, a significant payment penalty results. NAHC and Medicare’s MACs have advised hospices to check and double check information on NOEs and NOTRs prior to submission to ensure accuracy and limit financial loss.
  • CMS has identified four circumstances under which a hospice may request an exception to the NOE timely filing requirement ; however, none of these circumstances allows for human error or the lengthy processing times in CMS systems:
    • Fires, flood, earthquakes, or other unusual events that inflict extensive damage to hospice’s ability to operate
    • An event that produces a data filing problem due to CMS or contractor system issues, beyond the control of the hospice
    • Newly Medicare-certified hospice that is notified of certification after Medicare certification date, or awaiting user ID from Medicare contractor; or
    • Other circumstances determined by the MAC or CMS to be beyond hospice’s control
  • While CMS indicated it would not impose a specific penalty related to untimely NOTRs, hospices have been denied an exception for late acceptance of a NOE in cases where the patient was previously on service with the same hospice and late acceptance of the NOE was due to the hospice’s failure to submit a timely NOTR (or submit the final claim within 5 days of the discharge) for the previous hospice stay.
  • More recently, hospices have reported difficulties linked to submission of an NOTR containing an error and significant financial consequences. NOTRs with errors may not be simply deleted from the system; instead, the hospice must back out the NOTR, all claims associated with the hospice stay, and the initial NOE. The hospice must then resubmit the NOE, which will invariably be late.  In such instances, hospices may lose payment for the patient’s entire length of stay on hospice (which can amount to a significant amount of money) due to a single keystroke error.
  • As the transition to ICD-10 approaches, hospices are cautioned that beginning Oct. 1, 2015, a NOE or NOTR MUST include updated diagnosis codes; this includes ensuring that the NOE or NOTR does not contain a diagnosis code that is not permitted for use as a hospice principal diagnosis (such as a manifestation code). If ICD-9 codes are used in cases where ICD-10 codes are required, or the hospice mistakenly uses a manifestation or other code that is not permitted as a principal diagnosis, the notice may RTP and require resubmission. As noted above, in any cases where resubmission of a notice is required, there is a high potential for negative financial consequences.

While the hospice community supports CMS’ goal of ensuring that the CWF reflects timely and accurate information related to Medicare beneficiaries’ hospice status, the current process for submission of NOEs and NOTRs creates challenges for hospice providers at every turn, and allows for correction of human error without financial consequence in only very limited circumstances. NAHC and NHPCO have had discussions with CMS about these issues; CMS has indicated that major systems changes would be required to provide hospices improved opportunity to identify errors in NOE/NOTR submissions and address them in a fashion so as to avoid financial loss. These systems changes may take years to implement.

Given the high potential for errors that can have costly implications, we urge hospices to participate in the joint NAHC/NHPCO NOE/NOTR survey so that we can better quantify the impact of these timely filing requirements on the industry. Such data will be helpful in our future discussions with CMS and others on potential measures that can be taken to ease the burdens and risks associated with the timely filing requirements.




©  National Association for Home Care & Hospice. All Rights Reserved.