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  NAHC Report: Issue# 2765, 10/8/2015
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Comments Submitted on CMS’ Proposal to Allow Payment for Advance Care Planning Discussions
CMS Permits Initials on Amended and Delayed Entries
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Comments Submitted on CMS’ Proposal to Allow Payment for Advance Care Planning Discussions

The National Association for Home Care & Hospice (NAHC) has submitted comments to the Centers for Medicare & Medicaid Services (CMS) regarding CMS’ proposal to add new codes recognizing separate payment for advance care planning, as part of the proposed changes to the Medicare physician fee schedule in the Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2016. CMS proposed changing CPT codes 99497 and 99498 from “inactive” to “active” to allow payment for advance care planning discussions. CMS’ comment period on the proposal closed on September 8 (see previous NAHC Report article here), and according to reports CMS received approximately 600 comments regarding the advance care planning proposal, of which approximately 500 were in support.

NAHC, which has a long-held position supporting advance care consultations as part of patient planning and decision-making relative to serious illness, joined with other organizations earlier this year in urging CMS to include coverage of such planning in its 2016 physician payment rule. Following CMS’ release of the proposal, NAHC also submitted comments on the proposal to CMS in an individual letter, as well as in a group letter with other aging and health organizations, that expressed support for the new codes, and provided comments on the standards and goals that should be included in advance care planning conversations. “We applaud CMS for proposing this change,” NAHC stated.

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CMS Permits Initials on Amended and Delayed Entries

The Centers for Medicare and Medicaid Services (CMS) has issued Change Request (CR) 9332, which clarifies that amendments and delayed entities into medical documentation may be initialed and dated rather than signed and dated, which had been CMS’ policy

Occasionally, upon review a provider may discover that certain entries into the medical record at the time of service were not properly documented and need to be amended, corrected, or entered after rendering the service.

The CR instructs the Medicare contractors to accept confirmation of amendments or delayed entries to paper records that are initialed and dated, if the medical record contains evidence associating the provider’s initials with their name.

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The Largest Home Care and Hospice Marketplace in the World!

Register Today!

NAHC’s Annual Meeting, October 28-30 in Nashville, Tenn., is approaching quickly! We’re proud to bring together not only thought leaders and innovators for our panel discussions and education sessions, but also to our Expo, the largest home care and hospice marketplace in the world.

This year’s Expo is expected to feature nearly 200 specialists and vendors who understand the issues and challenges agencies are facing, and are there to talk with you about solutions. The conference includes 7.5 hours of time, including meals, set aside exclusively for attendees to spend in the Expo, networking with exhibitors.

The array of regulatory and other issues facing home care and hospice, such as changes with the OASIS-C1 data sets and the ICD-10 Coding Manual, adjustments in HHCoP’s and their QAPI requirements, and developments in telehealth regulation, can be tricky to navigate. The Expo at NAHC’s Annual Meeting is the best way to explore potential vendors and specialists who can help you address real problems in your business and care more effectively for your patients.

REGISTER NOW: Join us in “NAHCville” Tennessee, October 28-30!

  • Take an active role in bringing solutions back to your agency.
  • Network with experts about services and products making a real difference.
  • Gain valuable skills to make home care and hospice a better industry.

The Meeting begins at 4:30pm on October 28 for our first education session, so make plans to arrive on Wednesday and stay through the closing party on Friday, October 30.

Visit or follow us on Twitter at @OfficialNAHC for the latest updates on our session topics, exhibits, and faculty.

Assistant Vice President, Home Health/Hospice – Full Time


The Assistant Vice President, Home Health/Hospice executes direct administration of the Penn Highlands Healthcare System Home Health and Hospice departments as evidenced by achieving results in clinical quality, service excellence, human resources management and financial management. The Assistant Vice President assists in developing and implementing a strategic plan for the growth and development of the System's home health and hospice services.


  • 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 required;
  • 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

Penn Highlands DuBois is the best of modern health care technology, plus the best of small town America!

Located in the midst of the beautiful rolling hills and woodlands of Pennsylvania, you don't have to be a native to feel at home here. No matter where your roots, you'll quickly recognize that the staff at Penn Highlands DuBois (PHD), like other residents of the community, will make you feel right at home.

Penn Highlands DuBois (PHD) offers residents of west central Pennsylvania a rare combination of technologically advanced health care in a warm, friendly environment. Widely recognized as one of the leading health centers of its kind in the commonwealth, PHD is an oasis of clinical and technical excellence, with a focus on patient-centered care. Its rural setting is just far enough from the hustle of the city life to make it peaceful, but close enough to provide easy access to sought-after urban attractions.


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Please forward your resume and cover letter with salary requirements to Ann Bohac, HR Recruiter VNA Care Network & Hospice at    or visit our website at


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