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:: NAHC Report
  NAHC Report: Issue# 2718, 8/4/2015
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NAHC Files Brief in F2F Lawsuit; Court Hearing on August 6
CMS Posts Hospice Quality Reporting Updates
For Your Information: Registration is now open for NAHC’s 2015 Annual Meeting
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NAHC Files Brief in F2F Lawsuit; Court Hearing on August 6

The National Association for Home Care & Hospice (NAHC) filed its closing brief in the lawsuit challenging the Medicare rule that required physicians to compose a narrative following the patient face-to-face encounter to explain why the individual met the homebound and skilled care need elements of the Medicare home health services benefit. The now-rescinded narrative requirement triggered tens of thousands of claim denials based on Medicare contractors claiming that the narrative statements were insufficient to support the physician certification that the patient was homebound and in need of skilled care.  

Within weeks of NAHC’s lawsuit filing, the Centers for Medicare and Medicaid Services (CMS) dropped the narrative requirement from its rule. However, home health agencies nationwide were left with significant claim denials and financial losses stemming from the inconsistent and irrational administration of an unmanageable documentation standard. NAHC continues to litigate the validity of the narrative requirement to address an estimated $150-200 million in claim denials along with the risk that claims prior to the 2015 rescission of the rule could still be audited.

In its brief, NAHC argues that the plain language of the Affordable Care Act provision requiring a physician face-to-face encounter prohibits CMS from imposing the narrative requirement. In the alternative, the NAHC brief argues that the narrative requirement is an arbitrary and capricious rule in that it does not have a rational basis generally or in the context of the Medicare program as a whole. CMS has insisted throughout the litigation that it has the discretionary authority to require a physician narrative and that its implementation of such was reasonable.

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CMS Posts Hospice Quality Reporting Updates

The Centers for Medicare & Medicaid Services (CMS) has posted the following updates related to the Hospice Quality Reporting Program (HQRP) on its hospice quality-related websites:


IMPORTANT: Hospice providers should review all Final Validation reports to confirm successful submission and processing of HIS data (posted August 3, 2015)

As part of the HIS reporting requirements, hospices must submit required HIS–Admission and HIS-Discharge records to CMS’s Quality Improvement and Evaluation System (QIES) Assessment Submission and Processing (ASAP) system. In order to successfully submit records to the QIES ASAP system, HIS data must be converted into the proper electronic file format (XML) using either the Hospice Abstraction Reporting Tool (HART) software, which is free to download and use, or a vendor-designed software.

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Registration is now open for NAHC’s 2015 Annual Meeting

Registration for NAHC’s Annual Meeting is now open! The conference is October 28-30, 2015, at the Gaylord Opryland Resort & Convention Center in Nashville, Tennessee.

To register for the conference and to make your reservation at the Gaylord Opryland, click here.



Community Nurses, Inc. was named by Becker’s Hospital Review as one of the top 150 Great Places to Work in Healthcare in the United States for 2015 – Come join our team!


The Director executes direct administration of the Community Nurses Inc. System Home Health and Hospice departments, Adult Day Services and Support Services as evidenced by achieving results in clinical quality, service excellence, human resources management and financial management.  The Director assists in developing and implementing a strategic plan for the growth and development of Community Nurses Inc. services in collaboration with the AVP of Home Health/Hospice and other Penn Highlands Healthcare leadership.


  • Bachelors Degree in Nursing, Business Administration, or related field required; Masters Degree in Nursing, Business Administration, or related field preferred.
  • System management experience preferred.
  • Five years home health/hospice nursing experience preferred.
  • Two years management experience in home health/hospice setting required.
  • Demonstrates effective communication and collaboration skills with physician and all other members of the health care team
  • Progressive and successful work history
  • Specialty certification preferred

Interested candidates please submit a resume and cover letter for consideration. FAX:  814-788-8046 OR E-MAIL:


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