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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

Federal Court Rules In Favor of Medicare While Restricting Scope of F2F Narrative: Federal Court Decision Could Limit Medicare Power to Deny Claims Based on F2F Narrative Content

November 3, 2015 04:13 PM

U.S District Judge Christopher R. Cooper issued his decision today in the lawsuit brought by the National Association for Home Care & Hospice (NAHC) challenging the validity of the Medicare rule that a physician provide a narrative to document the face-to-face encounter with the patient. Judge Cooper ruled against NAHC and granted “Summary Judgment” to the U.S. Department of Health and Human Services. In his ruling, Judge Cooper found that the face-to-face law enacted by Congress was ambiguous and did not foreclose the interpretation of the word “document” that the Centers for Medicare and Medicaid Services (CMS) established in its regulations.

Under the standards for determining whether a federal agency regulation violates the congressionally-enacted law, the court first determines whether the plain language of the statute forecloses the specific regulatory interpretation. If the language of that law is at all ambiguous, the regulation is considered valid unless the interpretation is unreasonable, arbitrary, or capricious. NAHC argued that the statute limited the physician documentation to the date that the encounter occurred. The court concluded that the word “document” in the statute was ambiguous as it could include both the date of the encounter and a narrative of what the physician found during the encounter.

NAHC also argued that if the court found the statute to be ambiguous that Medicare’s interpretation was not reasonable as it led to such absurd results as claims denied based on the sufficiency of the narrative alone when the whole record of the patient supported Medicare coverage. The Court held that the narrative requirement was not unreasonable, arbitrary or capricious as it is a “reasonable way to verify that an appropriate encounter actually took place.”

While the Court rejected NAHC’s claim that a narrative requirement in the face-to-face physician encounter rule is invalid, the Court’s ruling provides a crucial conclusion that can help home health agencies succeed in winning reimbursement in appeals of claim denials based on an “insufficient narrative.”  Essentially, the court held that while a narrative requirement for documentation is a valid exercise of Medicare’s rulemaking power, Medicare cannot go beyond that narrative requirement and “second-guess the medical judgment of the patient’s physician” regarding the narrative content. That means that if the physician narrative presents patient clinical findings and explains why those findings support the need for home health services, the documentation requirement is met. Here is the part of the Court’s ruling that provides this important distinction.

Finally, it is important to note that this Court’s analysis would look very different if the rule allowed a Medicare claim reviewer to second-guess the medical judgment of a patient’s physician. For instance, if the rule authorized a reviewer to deny a claim—on the basis of insufficient documentation—simply because she disagreed with the physician’s clinical findings or the physician’s reasoning for why those clinical findings support a need for home-health services, that would go far beyond what the statute allows. HHS’s interpretive authority is limited to determining, within reason, how physicians should document that an appropriate face-to-face encounter actually took place—that is, that an encounter occurred that truly focused on determining whether a patient qualifies for home-health services. In making that determination, HHS chose to require physicians to describe their clinical findings and explain why those findings support the need for home-health services. In the Court’s view, the rule requires only that. To the extent HHS may have veered from that requirement in practice, home-care organizations that have been denied reimbursement on the basis of insufficient documentation are free to contest HHS’s implementation of its rule on a case-by-case basis. (emphasis added).               

NAHC is evaluating the next best steps to take on the ongoing face-to-face requirements controversy. It is expected that bicameral, bipartisan legislation will be introduced shortly that address both the current documentation standard as well as the now-abandoned narrative requirement that led to thousands of claim denials. Further, the import of the Court’s ruling is still under analysis regarding how best to use the conclusion that while a narrative requirement may be valid, it would be invalid to administer in a manner that allows Medicare to find a narrative is insufficient. The next steps in the litigation can include: an appeal to the U.S. Court of Appeals; a Motion for Reconsideration/Clarification; or settlement discussions.

Another alternative is for NAHC to undertake a consolidation of the individual appeals now pending administrative review or hearing before an ALJ. In doing so, NAHC can use the Court’s ruling to overturn decisions that are based on the narrative’s sufficiency. That would mean that unless the claim had no physician face-to-face narrative, it would be covered under Medicare. If a consolidated appeal is not possible, NAHC will develop a model legal memorandum to be used to support appeals with the narrative sufficiency in issue.

“Our fight to overturn these wrongful denials is not over,” expressed Val. J. Halamandaris, NAHC President. “We will take every course of action available to protect home health agencies from the wrongful denial of claims under the misguided physician narrative policy,” Halamandaris added.  

“We would prefer that the Court held the narrative requirement categorically invalid. However, in finding that the Medicare law does not permit CMS to deny a claim based on the sufficiency of the physician narrative, we believe we can reach the intended goal of getting claim denials reversed,” stated Bill Dombi, NAHC’s legal counsel in the litigation.

The ruling is here.




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