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

An Open Letter to CMS About Fraud

September 29, 2016 04:37 PM

The failure of the Pre-Claim Review Demonstration (PCR), begun in Illinois on August 3, 2016, is a very important subject to National Association of Home Care & Hospice, as any reader of the NAHC Report knows.

When we read this open letter to the Centers for Medicare and Medicaid Services (CMS) from the Center for Medicare Advocacy (CMA), we found ourselves impressed and in complete agreement. With their consent, we have reproduced it here for you

NAHC has joined forces with the Center for Medicare Advocacy in the fight to stop PCR. We are distributing the letter to Congress as part of our ongoing advocacy efforts. Unfortunately, the 87-year old victim referenced in the CMA letter is just one of the many examples of serious patient harm caused by PCR. NAHC has presented numerous other examples to CMS and our allies in Congress that demonstrate that the reviews are biased and incompetent, with quadriplegics found to be not homebound, patients with indwelling catheters to have no need for skilled care, and more. The introduction of legislation on Wednesday is a strong indication that Congress “gets it” and is on the side of Medicare beneficiaries and providers in this fight. CMS is not yet there, so we need to keep up the pressure by getting all members of the House to cosponsor H.R. 6226, the Pre-Claim Undermines Seniors’ Health (PUSH) Act.

The Center for Medicare Advocacy, Inc., established in 1986, is a national nonprofit, nonpartisan law organization providing education, advocacy and legal assistance to help older people and people with disabilities obtain fair access to Medicare and quality health care. The Center is headquartered in Connecticut and Washington, DC with offices throughout the country.

An Open Letter to CMS About Fraud

Can we talk about fraud? It exists. It’s not good for Medicare. Efforts to eliminate its damage to the program are necessary.  But CMS’ war on fraud seems to be indiscriminate, full of tactical errors and collateral damage. Rather than carefully targeting the perpetrators of fraud, a wide net is cast, resulting in legitimate claims for necessary care sinking into a sea of denials.

The latest victims include an 87-year-old woman suffering from congestive heart failure, an individual in need of wound care and gait training to remain safely at home, and a person with multiple sclerosis requiring significant ongoing physical therapy. These are examples of denials made in the new Home Health Pre-Claim Review Demonstration Model (PCRD) launched last month in Illinois. While the Demonstration is still active in Illinois, further application in other states has been suspended as a result of myriad problems with legitimate claims.

The premise of pre-claim and prior-authorization reviews might seem to make sense – in theory, they require documentation for claim approval up-front instead of later in the process, after the delivery of care. In a perfect world, all the pieces that need to come together would be completed and submitted when a person seeks care. The physician or other provider would produce all the necessary documentation in the correct format, all the required evaluations and assessments would be flawlessly completed by skilled nurses and therapists, and the information would be submitted in the specific order required by the Medicare contractor. But, too often, pre-claim review and prior authorization just become excuses for pre- or prior- denial. When up to 80% of claims are denied because they have not achieved the prescribed perfection required, beneficiaries are denied access to necessary care and providers are reluctant to offer care in the future.

After correcting difficulties uploading documents and other technical glitches in the PCRD, two major problems continue to surface. The first problem is with the tightly dictated standardized formatting that the Medicare contractor requires in order to process pre-claim approvals. The second concerns issues with the face-to-face certification requirements.

The “User Guide & Checklists” for the “Home Health Pre-Claim Review eServices Submittal Request”, while intending to be comprehensive, creates an impractical bar for home health agencies. When one piece of data is not provided in a very specific format, and in the prescribed order, the entire claim is denied. The level of detail requires a clinically educated person to review every case to tease information out of every record to complete the required forms. Since there is no standardized practice by which providers (e.g. doctors/therapists/hospitals) write chart notes, narratives, and orders, this new system – that apparently assists review for the Medicare contractor – is a nightmare for the home health agencies. They are overwhelmed by the requirements, which serve no apparent substantive purpose, but which have quickly impacted access to care for beneficiaries.

Under the PCRD, all the required documentation from the providers (completed, signed and dated correctly) must be chased down up-front, rather than in a manner that allows time for the agencies to get the documentation from the doctors and other providers. Again, this creates obstacles to care for beneficiaries.

Successfully completing the face-to-face provider’s certification requirement is another great challenge in the PCRD, still further jeopardizing care access for beneficiaries. While requirements of this certification have been unclear since its implementation in 2011, the issues with face-to-face certifications became worse in 2015 (ironically, when the narrative requirement was dropped and the standards became more ambiguous). Pre-claim reviews are further highlighting the poorly designed, implemented, and inconsistently applied face-to-face requirements.

Additional documentation requests (ADRs) for the face-to-face certifications occurred about .5% of the time until the PCRD. Under PCRD, face-to-face certification scrutiny occurs 100% of the time - and now two doctors may be required to coordinate and to sign (if the patient is coming from a facility, the hospitalist and the primary care doctor). Guidance about how to complete face-to-face certifications have not allowed physicians, who are not compensated for the time necessary to complete these, to meet all the required, and often inconsistently interpreted, criteria. The legal definitions the reviewers are looking for are well outside the “wheelhouse” of doctors. Denials of face-to-face certifications are based on trivial and technical issues and miss the original intent of the requirement, which was to ensure a physician is aware of, and orders, the home health care. This causes understandable frustration for physicians, home health agencies, and beneficiaries.

Pre-claim reviews and prior-authorization may be intended as tactics in the battle against fraud, but in practice they are working to further interfere with legitimate claims for necessary care. They are eroding Medicare’s promise to provide necessary care for older people and people with disabilities, and harming the program’s integrity. There are other approaches to defeating Medicare fraud that CMS could adopt from other public concerns, such as “see something, say something,” neighborhood watches, or peer review. 


The PCRD is an inappropriate, over-inclusive counter to fraud. Medicare reports that 90% of potentially fraudulent activity in Medicare home health care is actually “insufficient documentation.”[1]However, insufficient documentation is not a valuable link to significant fraud. As a CMS official recently stated, major bad actors know very well how to provide documentation.

Medicare beneficiaries in real need of home health care are facing increasing access problems.  We urge CMS not to add to these barriers with technical claim requirements and inappropriate prior denials that encourage providers to stop offering care. The Pre-Claim Review Demonstration Model should be ended before it causes more harm to older people, people with disabilities, and their families.

[1]Supplementary Appendices for Medicare Fee-For-Service 2014 Improper Payments Report.​Items/Downloads/AppendicesMedicareFee-for-Service2014ImproperPaymentsReport.pdf




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