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  NAHC Report: Issue# 2900, 5/6/2016
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NAHC Submits Formal Comments on Provider Enrollment Rule Proposed Changes
CMS Holds Latest Home Health, Hospice, & DME Open Door Forum
For Your Information:Home Health & Financial Management for FMC Insiders
Job Corner: Seeking a President for Home Care — State Programs Division
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NAHC Submits Formal Comments on Provider Enrollment Rule Proposed Changes

The Centers for Medicare and Medicaid Services (CMS) published a Notice of Proposed Rulemaking  that includes significant changes to provider enrollment requirements along with proposals to change the moratoria authority rule and expand the requirements that physician that order, certify, or refer Medicare patients be enrolled in the Medicare system. These proposals may seem technical and innocuous, but each of them can have significant impact on a provider’s status in Medicare and Medicaid. The National Association for Home Care & Hospice (NAHC) submitted formal comments to CMS on these proposals, recommending a series of modifications and clarifications.

At the outset of its comments, NAHC suggests that all Medicare/Medicaid program integrity measures should be evaluated against a comprehensive set of guiding principles. The recommended set of 10 principles include:

  1. The program integrity measure must be best targeted to the fraud, waste, and abuse of concern.
  2. Program integrity measures should be evidence-based with a demonstrated return on investment.
  3. The most effective program integrity measures are those that avoid or prevent fraud, waste, and abuse.
  4. Stakeholder support is essential to achieving success in program integrity.
  5. Program integrity measures should be developed in a transparent manner that assures the opportunity for public input.
  6. There must be clear legal authority for any program integrity measure.
  7. A program integrity measure should not erect a barrier to appropriate care access.
  8. The least burdensome method of dealing with Medicare fraud and abuse is the best path to success.
  9. Any reforms or remedies should properly distinguish fraud from unintentional noncompliance.
  10. The outcome of the program integrity measures should be reliable with no “innocent victims” resulting.

NAHC concludes that the proposed changes meet most of these standards, but not all unless modifications are made for the Final Rule.

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CMS Holds Latest Home Health, Hospice, & DME Open Door Forum

The Centers for Medicare & Medicaid Services (CMS) held a Home Health, Hospice, and Durable Medical Equipment (DME) Open Door Forum (ODF) on May 4, 2016.  Relative to home health and hospice, the CMS panel shared information on the following:

  • FY2017 Hospice Notice of Proposed Rule Making (NPRM)
  • Medicaid home health face-to-face (F2F) final rule
  • Home health value based purchasing
  • Home Health CAHPS
  • Home health star ratings
  • IMPACT Act

Please note:  CMS will have a recording of the ODF available until 5 p.m. EASTERN on Friday, May 6, that may be accessed by calling:  1-855-859-2056 and using conference ID:  39979021.

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Home Health & Financial Management for FMC Insiders

FMC with NAHC and HHFMA is the ultimate opportunity to connect with industry leaders.  As financial mangers in home care you face new challenges every day, whether it’s internally with regard to wage and hour complexities, or with new CMS regulatory updates. 

Home health is all about value.  Stipulations of the Affordable Care and Patient Protection Act encourage the formation of ACOs and other strategic partnerships with care providers to foster more affordable, high-quality care options.  At FMC, you’ll learn how to develop collaborative relationships that build and sustain ACOs, while improving internal processes and procedures.  Learn how to excel in this value-based healthcare environment.

Learn more about FMC 2016!  See the conference program and schedule here.

Register for discounted attendee hotel rates at the Las Vegas Red Rock Casino & Spa and the conference itself here.

Seeking a President for Home Care — State Programs Division

We are BAYADA Home Health Care—a leading mission and values based home health care company—and we believe that our clients and their families deserve home health care delivered with compassion, excellence, and reliability.

We are actively looking for a President for our Assistive Care State Programs specialty practice, which is concentrated in NJ, PA, NC, DE, & MA and currently represents $150M in revenue with growth potential of $1B over the next 10 years. Candidates need to have experience in general management for a complex operating business, and demonstrated success working within state and federally funded programs. S/he should have a proven track record in the development and implementation of strategic growth plans, including the ability to operationalize strategies across multiple states.

Founded in 1975 by J. Mark Baiada, BAYADA Home Health Care provides nursing, rehabilitative, therapeutic, hospice, and assistive care services to children, adults, and seniors in the comfort of their homes. Headquartered in suburban Philadelphia, BAYADA employs more than 19,000 nurses, home health aides, therapists, medical social workers, and other home health care professionals who serve their communities in 22 states from more than 300 offices.

Interested candidates should reach out to

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