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NAHC Report: Issue# 2341, 12/26/2013
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PECOS Tips as Edits Draw Near
NAHC Year in Review: Legal and Some Regulatory Issues
For Your Information: 2013 NAHC Annual Meeting Certificates for Attendees are Now Available Online
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PECOS Tips as Edits Draw Near

January 6, 2014 is the date for activation of the Internet-based Provider Enrollment, Chain and Ownership System (PECOS) edits that will result in denial of home health claims if the ordering physician is not enrolled in PECOS or officially opted-out of Medicare. In order to protect against non-payment by Medicare, home health agencies must verify enrollment of all ordering physicians.

Beneficiary Notification

The Centers for Medicare & Medicaid Services (CMS) clarified in their most recent communication (MLN Matters Article SE 1305) that claims denied because they failed the ordering/referring edit will not expose a Medicare beneficiary to liability. Therefore, an Advance Beneficiary Notice is not appropriate in this situation. CMS also informed the National Association for Home Care & Hospice (NAHC) that since the beneficiary can not be held liable for services ordered by a provider who is not registered in PECOS, no notice is to be given because the beneficiary can not be charged.

CMS’ position would prohibit the beneficiary from choosing to privately pay for services even if informed of Medicare non-payment in advance of the initiation of care. NAHC has expressed its disagreement with this policy and requested that CMS reconsider their position. NAHC advices that home health agencies should not initiate services for beneficiaries who are unable to identify a PECOS-enrolled physician to assume ordering responsibilities for episodes of care beginning on and after January 6.

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2013 NAHC Annual Meeting Certificates for Attendees are Now Available Online

The 2013 NAHC Annual Meeting certificates are now available online and ready to download for participants and attendees to this year’s Annual Meeting.

Please click here to download your certificate.

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NAHC Year in Review: Legal and Some Regulatory Issues

2013 was an eventful year within the legal and regulatory realms for home care and hospice providers. Below are the most significant developments from the legal and certain regulatory issues from this past year:

  1. Obama Administration delays the start of the employer mandate provisions of the health care reform law

Responding to the pleas of thousands of small businesses in home care and otherwise, President Obama moved the effective date of the ACA provision mandating that companies either provide health insurance to their employees or pay significant monetary penalties. A NAHC study showed that the vast majority of home care companies, particularly those that provide Medicaid and private pay services, do not currently provide all full-time workers with health insurance.  NAHC advocated for the delay, explaining to administration officials that care access would be significantly jeopardized by these requirements.

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