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

NAHC Submits Comments to OMB on CMS’s Proposed Pre-Claim Review Demonstration for Home Health Services

July 23, 2016 08:54 AM

The National Association for Home Care & Hospice (NAHC) recently submitted comments to the Office of Management and Budget (OMB) regarding the proposal from the Centers for Medicare & Medicaid Services (CMS) to institute a system of “pre-claim review” on all home health services in five states. Those states are Illinois, Florida, Michigan, Texas, and Massachusetts. Illinois is up first on August 1.

In its comments to OMB, NAHC states that the proposed program “falls short of what it takes to be an effective program integrity tool sufficient to offset the down-side risks to Medicare beneficiaries and upstanding home health agencies,” and recommends that the proposal be withdrawn.

NAHC argues that the downside consequences include the fact that the proposed program:

  • is not sufficiently targeted to the fraud or abuse of concern
  • is not evidence-based with demonstrated return on investment
  • does not prevent fraud
  • is absent adequate legal authority
  • erects barriers to appropriate care access
  • would be excessively burdensome
  • fails to distinguish between fraud and unintentional noncompliance and would be highly likely to lead to a significant number of “innocent victims” through care delays, extended stays in high risk settings and wrongful rejections of authorization

The proposed program “violates standards of reasonableness, economy, and efficiency,” NAHC states. “The proposal is untargeted, with high administrative costs and operational burdens, is likely to create improper barriers to access to timely care, would not be effective against the fraud concerns in Medicare home health services, and would not aid in achieving a higher degree of compliance with the alleged claim documentation deficiencies.”

NAHC further states “there is no legal authority for the proposed pre-claim review demonstration program.” 42 USC Section 1395b-1(a)(1)(J) provides limited and qualified authority to CMS “to develop and engage in experiments and demonstration projects” in order “to develop or demonstrate improved methods of investigation and prosecution of fraud.” NAHC states that the proposal “does not comply with the congressionally expressed authority for a demonstration program of this nature.”

In fact, NAHC states, the “Supporting Statement” accompanying the pre-claim review Paperwork Reduction Act notice did not even attempt to define the nature of the fraud that the project would address. Instead the program claims to tackle improper payments with reference to the 2014 Comprehensive Error Rate Testing (CERT) results that report an improper payment rate of 51.4% compared to the FY 2013 report of 17.3%. However, NAHC notes that FY 2014 was the year in which CMS expanded its claims reviews for compliance with the physician face-to-face encounter requirements, which led to an upsurge in claims denials. “However, those denials, like the CERT results, were due to allegations of insufficient documentation, not fraud. The Supporting Statement verifies such in noting that 90% of the CERT reported errors were from ‘Insufficient Documentation.’” NAHC further notes that the proposed program would “focus only on garden-variety disputes on claim documentation while not operating to address the now-rescinded face-to-face encounter documentation issues at the center of the CERT results.

Further questioning the legal authority of the proposed program, NAHC notes that Congress has limited the use of prior authorization to certain items of Durable Medical Equipment (DME), and that any proposal to implement a pre-claim review system must be promulgated through formal rulemaking.

NAHC challenges the CMS estimate of costs for the project and emphasizes that CMS has not demonstrated that it would be worth the expense. CMS estimates that the costs to Medicare would be nearly $300 million over three years. NAHC explains that the estimate is based on the original “prior authorization” proposal where 908,000 claims reviews would be required. With the current project, those reviews could triple since CMS allows providers to request a pre-claim review multiple times. That increased volume could bring Medicare costs exceeding $1 billion.

In addition, NAHC disputes CMS’s estimate of 30 minutes of clerical time for home health agencies. Instead, NAHC survey data shows a 1-2 hour time expense with both clinical professionals and clerical staff involved, creating a cost estimate of over $100 per claim review.  

“Overall, the proposed collection activity is based on a demonstration project plan that is not authorized under Medicare and is implemented in a manner wholly inconsistent with Medicare law, the Administrative Procedures Act (APA), and the Small Business Regulatory Flexibility Act,” NAHC states. “Further, the underlying project significantly increases Medicare costs and the paperwork cost burdens for home health agencies without a justifiable return on that cost. Medicare has numerous alternative actions that can be taken that do not impose the level of burden as presented with this project with equal of better outcomes for Medicare and program stakeholders.”

For these reason, NAHC “respectfully recommends that OMB instruct CMS to withdraw its proposal for prior authorization in home health services.”

To read NAHC’s full comments, click here.




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