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NAHC Report: Issue# 2522, 10/7/2014
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CMS Proposes New Home Health Conditions of Participation
Part D Prior Authorization Form – Medicare Beneficiaries Enrolled In Hospice
For Your Information: Continuing Education Credits Now Offered for Nursing Home and Assisted Living Administrators at NAHC’s Annual Meeting
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CMS Proposes New Home Health Conditions of Participation

The Centers for Medicare and Medicaid Services has issued the long-awaited Home Health Conditions of Participation (HHCoPs).

Home health agencies (HHAs) must meet the Medicare HH CoPs in order to participate in the Medicare program. Agencies that fail to meet any of the HH CoPs are at risk, at a minimum, for the imposition of a number of sanctions and potentially at risk for program termination. 

Although CMS has made several significant revisions to the HH CoPs throughout the years, many of the current CoPs have remained unchanged since their inception. In 1997, CMS attempted to revise the HH CoPs with a proposed rule that focused on patient-centered outcome oriented quality standards. However, since CMS did not publish a final rule within the required three years time frame, the proposed rule was rescinded and CMS must issued anther proposed rule.

CMS maintains it commitment to revise the HHCoPs with a focus on a patient-centered, data driven, outcome-oriented process that promotes high quality of care, while at the same time eliminating unnecessary procedural burdens on HHAs.  

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Part D Prior Authorization Form – Medicare Beneficiaries Enrolled In Hospice

CMS is asking for comments on a proposed Part D prior authorization form to be used for Medicare beneficiaries enrolled in hospices.  The OIG and CMS have identified concerns that Medicare Part D may be paying for medications that should be provided and covered by hospices.  As a result, CMS proposed and implemented a prior authorization process in 2014 and updated that guidance in July of 2014.  The updated guidance calls for beneficiary-level prior authorization (PA) requirements on the following four categories of prescription drugs identified by the OIG as typically used to treat the common symptoms generally experienced during the end of life: analgesics, anti-nauseants (antiemetics), laxatives, and antianxiety drugs (anxiolytics).  In order for a drug to be covered under Medicare Part D while a beneficiary is enrolled in the Medicare hospice benefit, the drug must be completely unrelated to the principle hospice diagnosis and/or any related conditions.

The industry in conjunction with the National Council for Prescription Drug Programs, (NCPDP) has developed a standard form that with minor modifications will meet the program needs. CMS will encourage use of this form as soon as it is approved and will likely propose requiring its use in future rulemaking.  The standard form provides a vehicle for the hospice provider, prescriber or sponsor to document that the drug prescribed is “unrelated” to the terminal illness and related conditions. It also gives a hospice organization the option to communicate a beneficiary’s change in hospice status and/care plan to Part D sponsors.

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Continuing Education Credits Now Offered for Nursing Home and Assisted Living Administrators at NAHC’s Annual Meeting

NAHC is proud to announce the addition of continuing education (CE) credits for Nursing Home Administrators and Assisted Living Administrators. These offerings, in addition to the CEs currently offered by NAHC for continuing education programs for Nurses, Accountants, Physical Therapists and Social Workers, provide an effective way to complete continuing education requirements, and get needed tools and insight to meet the challenges of the future.
Among the following programs that have been approved for credits for Nursing Home Administrators and Assisted Living Administrators are:

  • How to Leverage Care Management Services to Build Strategic Referral Partnerships
  • How to Establish Partnerships and Opportunities for Home Care Providers in Working with Medical Homes
  • How to Determine Objectives, Priorities and Effectiveness: Post-Acute-Care Compliance
  • How to Use Community-Based Connected Care for Chronic Disease Management: A Nontraditional Approach
  • How to Plan and Package Care Transitions: A Provider's Perspective

The NAHC Annual Meeting is being held at the Phoenix Convention Center, October 19 – 22, 2014, in Phoenix, AZ.

To view all education opportunities, click here.

To register for the Annual Meeting, click here.

Registered Nurses and Hospice Staff

Renown Health, based in Reno, Nevada, is looking for experienced, supportive Registered Nurses and hospice staff.

In keeping with our commitment to providing compassionate and continuum care at every stage of life, we are opening Renown’s first-ever hospice program and we're looking for experienced RNs and hospice staff with at least two years of prior hospice experience.

Renown Health is northern Nevada’s largest integrated health network and a nationally recognized healthcare leader. Based in Reno, Renown serves a 17-county region comprised of northern Nevada, Lake Tahoe and northeast California. The Reno-Tahoe region holds a range of lifestyle options that spans from downtown Reno to the shores of Lake Tahoe. With over 300 days of sunshine annually, it’s easy to understand why so many people choose to explore the natural beauty of our region. Experience as much or as little as you want as you thrive in our small-town feel and friendliness and all the financial benefits that come from a state with no state income tax.

Learn more at: or contact Anne Larson, Recruiter, at 775-982-6306. EEO/M/F/V/D


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