Skip to Main Content
National Association for Home Care & Hospice
Twitter Facebook Pintrest
:: NAHC Report
NAHC Report: Issue# 2401, 3/27/2014
Follow us on:     
NAHC Lawsuit Against CMS Over Face-To-Face Announced at the March on Washington
OIG Issues Report on Home Health Payments and OASIS Submissions
For Your Information: CMS Announces the OASIS C1 Webinar
NAHC/Home Care & Hospice Events
Email Center
Manage Your Account Contact the Editor Ensure Delivery Advertise in NAHC Report

NAHC Lawsuit Against CMS Over Face-To-Face Announced at the March on Washington

It was announced at NAHC’s March on Washington, which concluded earlier this week, that the National Association for Home Care and Hospice (NAHC) is planning to file a lawsuit against CMS regarding the face-to-face requirement that was part of the Affordable Care Act.

Below is the text of a recent Inside Health Policy articlein its entirety that addresses NAHC’s planned lawsuit, reprinted with the publisher’s permission:

NAHC Plans To Sue CMS Over ACA’s Home Health Face-To-Face Requirements 

The National Association for Homecare and Hospice is laying the groundwork to sue CMS next month over its implementation of the Affordable Care Act's home health face-to-face documentation requirement, as providers’ frustration has mounted with face-to-face denials and requirements to meet unknown standards in order to be paid for care provided in good faith, Inside Health Policy has learned.

Bill Dombi, vice president for law at the NAHC, told members at NAHC’s "March on Washington" meeting that the lawsuit will be crafted as a cry for help. Dombi said that providers have tried unsuccessfully to talk with CMS multiple times, and maybe the parties need a mediator. Dombi said the hope is CMS will not take the lawsuit as a "shot across the bow" but a flag of surrender from providers looking for better guidance and clarity.

:: Read Full Article

OIG Issues Report on Home Health Payments and OASIS Submissions

The Office of Inspector General (OIG) has issued a report of its audit of home health payments in six New England states concluding that many of the audited claims should be denied payment because the required OASIS had not been submitted to the State survey agency or had not been accepted as submitted.

The OIG found:

The RHHI paid Medicare claims for which HHAs had not submitted the required OASIS data. Of the 100 claims that we sampled, the RHHI made payments totaling $156,722 for 65 claims that should not have been paid. Specifically, 36 claims should not have been paid because the HHAs had not submitted accepted OASIS data at the time of payment, and 29 claims should not have been paid because HHAs had not submitted accepted OASIS data. We estimated that the RHHI made approximately $25.1 million in Medicare overpayments because it did not deny claims that HHAs had submitted without the OASIS data, which is a condition of payment.

Overpayments occurred because HHAs often had inadequate controls for the submission of OASIS data. Furthermore, Medicare payment controls were inadequate to prevent or detect payments to HHAs for claims that were missing accepted OASIS data. Without adequate controls, CMS has a limited ability to prevent payments to HHAs that have not submitted accepted OASIS data.

:: Read Full Article

CMS Announces the OASIS C1 Webinar

On, April 30, 2014, the CMS Survey and Certification Group is sponsoring a webinar on “OASIS-C1”. The topics of this hour and a half-long webinar include:

  • The new OASIS-C1 data set and its implementation, scheduled for October 1, 2014;
  • Types of changes made to the data set;
  • OASIS-C1 Guidance Manual changes; and
  • OASIS Q&As update.

There will not be a live Q&A session at the end of the presentation. Questions related to OASIS-C1 and its guidance should be submitted prior to and following the webinar to the OASIS mailbox at:

Following the webinar, a Q&A document will be posted addressing questions previously submitted.

A total of 1,000 lines for this webinar have been reserved. All participants will be in the same queue, so participants are encouraged to call in up to 30 minutes ahead of start time. The webinar will be archived within 3-4 weeks after the live presentation.

The intention of the webinar is to provide important guidance related to the implementation of the OASIS-C1 data set scheduled for implementation on October 1, 2014, therefore providers are encouraged to attend this webinar. Webinar materials will be forthcoming prior to the webinar and posted here.

Webinar Instructions for HHAs and other participants:

  1. On the day of the webinar go directly to
  2. From the Adobe Connect Meeting window, type your name in the “Guest Box.”

Page 3 – State Survey Agency Directors

  1. Press “Enter Room” to access the webinar.
  2. Dial into audio bridge number, (877) 251-0301 (Conference ID: 9431125) to hear the audio portion of the Webinar.
For webinar technical questions contact Etolia Biggs at, 410-786-8664.


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