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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

Heath 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

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

CMS Data on Illinois Pre-Claim Review is Misleading

October 13, 2016 03:42 PM

The Centers for Medicare and Medicaid Services released “Early Data from Illinois,” regarding the pre-claim review (PCR) demonstration program begun in that state on August 3, 2016.

The CMS attempts to project a relatively benign image of the PCR demonstration, the truth is that the data presented and the data that is missing both indicate that the problems PCR has created for home health agencies (HHA) and their patients are significant and, if anything, growing worse.

CMS indicates that 91 percent of review requests were submitted through the contractor’s online portal, with the time to complete the submission dropping from a 12-minute average to nine minutes by week eight. However, this data is highly misleading and does not include the extensive time needed to collect the documentation for submission or the time it takes to review all the documentation for compliance. Assembling, reviewing and submitting this documentation is a new requirement under the PCR experiment and an HHA study shows that the new functions take nearly one hour of nurse time per pre-claim review submission, not merely the 9-12 minutes spent online at the contractor’s portal.

CMS boasts that reviewers provided decisions within the required time frames more than 99 percent of the time. However, most HHA have submitted only a fraction of their pre-claim review requests because they are holding submissions while attempting to determine the outcome of a sample of their claims. CMS has confirmed it has received fewer submissions during the same period of 2015, but has not disclosed the actual number of submissions. In other words, CMS has yet to come anywhere close to seeing the workload level that actually exists in Illinois. NAHC believes CMS should be asked to disclose its current workload in PCR, along with its monthly pre-PCR workload for Illinois.

The combination of provisionally affirmed and partially affirmed decisions has increased to 66 percent, with a non-affirmation rate of 34 percent, according to CMS. CMS indicates this is an improvement over the 2015 national improper home health payment rate of 59 percent. But what sort of improvement is that really? Medicare spending on home health services in Illinois exceeded $1 billion in 2015, so a 34 percent rejection rate would equal almost $350 million of unreimbursed care. That equates to $58 million in un-reimbursed care for the first two months of the PCR demonstration alone! Those losses are unsustainable and HHA cannot survive much longer with a 34 percent rejection rate.

More crucially, however, is that Medicare beneficiaries are the ones suffering the most. They cannot withstand a 34 percent rejection rate; it is a direct barrier to care access. HHA with a 34 percent non-affirmation rate restrict patient admission and delay the start of care until an affirmation is received, which is not good for the patient and far costlier in the long run. Furthermore, patients subject to a PCR rejection terminate their own care to avoid a crippling financial liability in the future. There is a very high risk that such patients will require hospitalization because they did not receive the home care they need.

CMS presents the proverbial apples to oranges comparison by noting that the non-affirmation rate is lower than the 2015 national improper payment rate of 59%. The 59% calculation is based on the amount paid for home health services that the CERT evaluation concluded should not be paid. It is the ratio of the total dollar improperly paid to the total dollars paid. The 34 percent metric in the CMS report is a ratio of total pre-claim submissions to pre-claim submission non-affirmations. These are completely different calculations.

The rejection rate is also higher than the reported 34 percent. CMS does not disclose the level of partial affirmations, yet includes them in its calculation as equivalent to full affirmations. This is nonsense. A “partial affirmation” is a partial denial. The financial impact of partial affirmations can be significant. For example, if an HHA submits a pre-claim review for a plan of care that would result in a $3000 episode if fully accepted, it can result in a partial affirmation with only $300 of the physician-prescribed services approved. It is crucial to understand specifically what the distribution of full affirmations and partial affirmations is in the PCR data along with an understanding of the financial impact on the claim payment amount as HHAs are incurring the full cost of the services rendered.

CMS reports the most common reasons for non-affirmation include:

Skilled nursing/therapy not medically necessary or documented

25 percent

Homebound status not documented

18.6 percent

Face-to-face missing/incomplete

5.6 percent

Other documentation errors

50.8 percent


This data is highly inconsistent with the CERT report, which shows “insufficient documentation” as the reason for 94.8 percent of errors. Medical necessity errors comprise a mere 4.1 percent of the alleged errors. What’s more, in reality, virtually all non-affirmations list multiple reasons for rejection. In fact, it is not uncommon for all four reasons listed above to be cited as reasons for rejection.

While the CMS touts its PCR education efforts, the truth is that the CMS and MACs are making their own mistakes. The evidence for MAC policy errors, claim review errors and blatantly bad pre-claim review decisions is piling up.

The truth is that PCR was not necessary for CMS to provide enhanced education and support to reduce errors. Through the CERT program, CMS has already identified the nature of HHA documentation errors. Instead of spending hundreds of millions of Medicare dollars on a pre-claim review process intended to correct errors, CMS could have spent a fraction of that money educating providers, physicians, MACs and beneficiaries on Medicare coverage requirements and reforming outdated, confusing and often unmanageable documentation policies.

While the CMS data is useful in proper context, HHA and patients cannot absorb the cost of a 34 percent rejection rate that CMS is celebrating as an improvement. The administrative burden of PCR continues to be excessive and that burden will only grow as HHA submit thir backlog of claims. The information gathered to date by CMS through the CERT evaluations and the PCR project in Illinois is more than enough to permit CMS to develop a targeted educational and documentation policy reform effort that can successfully correct any systemic errors. The resources are better spent on corrective actions that go to the root causes of documentation errors instead of continuing a burdensome project that has served it purpose sufficiently.




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