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NAHC Report: Issue# 2567, 12/12/2014
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NAHC Sends Letter to CMS Proposing a Phase-in Approach to the Face-to-Face Requirement
CMS Releases Proposed Rule that will Affect Hospices
For Your Information: New Items Added to NAHC’s Ebola Task Force Resource Center
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NAHC Sends Letter to CMS Proposing a Phase-in Approach to the Face-to-Face Requirement
Letter offers steps CMS should take to phase-in the Face-to-Face requirement to ease the Jan. 1 start date

Last week, NAHC President Val J. Halamandaris sent a letter to the Centers for Medicare and Medicaid Services (CMS) Administrator Marilyn Tavenner urging a phased-in approach to the new face-to-face documentation requirements. The new requirements are scheduled to take effect on January 1, 2015.

The letter highlights CMS’ past willingness to phase-in new requirements, as well as reiterating the challenges that both home health agencies and physicians will face if the new requirements are not phased-in:

“The new documentation requirement takes effect on January 1, 2015. However, CMS has not yet issued any interpretive guidance on the rule change nor has there been any educational efforts directed towards physicians or home health agencies on it. While an “Open Door” call is scheduled for December 16, it is highly likely that any information conveyed in that call will not be conveyed to all the physicians and home health agencies that care for home health patients sufficiently to bring about full compliance by January 1. It is also likely that there will be many unanswered questions remaining after the call that will require CMS to issue further guidance.

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CMS Releases Proposed Rule that will Affect Hospices
Proposed rule will ensure CMS recognizes same-sex marriages for Conditions for Coverage and Conditions for Participation in Medicare and Medicaid

The Centers for Medicare & Medicaid Services (CMS) issued a proposed rule [CMS-3302-P] to revise selected Conditions of Participation (CoPs) for providers, Conditions for Coverage (CfCs) for suppliers, and requirements for long-term care facilities, to ensure that certain requirements are consistent with the Supreme Court decision in United States v. Windsor, 570 U.S. 12, 133 S.Ct. 2675 (2013), and U.S. Health and Human Services policy.  This Supreme Court decision is related to the Defense of Marriage Act. 

This proposed rule addresses certain regulations governing Medicare and Medicaid participating providers and suppliers where current regulations look to state law in a matter that implicates - or may implicate - a marital relationship. CMS’ goal is to provide equal treatment to spouses, regardless of their sex, whenever the marriage was valid in the jurisdiction in which it was entered into, without regard to whether the marriage is also recognized in the state of residence or the jurisdiction in which the health care provider or supplier is located, and where the Medicare program explicitly or impliedly provides for specific treatment of spouses.

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New Items Added to NAHC’s Ebola Task Force Resource Center

NAHC’s Ebola Task Force recently updated its Online Resource Center with additional documents that many be useful in preparing home care and hospice professionals with the latest information on combating the virus.

To view the newest resources, and to learn more about NAHC’s Ebola Task Force, please click here.

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