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  NAHC Report: Issue# 2920, 6/6/2016
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NAHC Advocacy Leads CMS to Rethink Electronic Submission of NOE/NOTR
Rep. Ellmers Cosponsors the Home Health Care Planning Improvement Act
For Your Information: How to Avoid Risk while Meeting Care Needs: Getting Hospice GIP and Continuous Care Right!
Job Corner: 1) Home Health Executive Director; 2) Education Coordinator/HHA Department Manager
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NAHC Advocacy Leads CMS to Rethink Electronic Submission of NOE/NOTR

In response to advocacy by the National Association for Home Care & Hospice (NAHC), the Centers for Medicare & Medicaid Services (CMS) is now actively pursuing efforts to allow for use of the institutional claim (837I) to submit hospice Notices of Election (NOEs) and related transactions via Electronic Data Interchange (EDI). This action, in CMS’ words, “would reduce, and potentially eliminate, problems with NOEs that result from errors during the Direct Data Entry (DDE) process.”  CMS’ Provider Billing Group is currently in discussions with its National Standards Group (NSG) in the Office of Enterprise Information to explore the potential for allowing hospices to submit NOEs via EDI using a non-standard implementation of the 837I transaction. Once the Provider Billing Group receives an opinion from NSG and has planned its next steps, it will provide a status report to NAHC.

Since October 2014, one of the most administratively burdensome and costly issues that hospices have dealt with has been meeting the timely filing requirements for NOE and Notices of Termination/Revocation (NOTR). Since that time the National Association for Home Care & Hospice (NAHC) and other stakeholders have worked diligently to address the growing number of problems associated with the timely filing policy. Last year NAHC and NHPCO jointly sponsored a hospice survey to help quantify NOE/NOTR-associated costs and financial losses, and the findings of the survey indicated that the financial impact of the requirement has been considerable. Over the last year NAHC has also sought a number of clarifications from CMS and its Medicare Administrative Contractors (MACs) with the goal of easing some of the negative consequences of using direct data entry (DDE) to meet these time-sensitive requirements. While some of these efforts have met with success, each -- on its own -- has made only a relatively modest impact overall, and additional problems continue to emerge in this area.

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Rep. Ellmers Cosponsors the Home Health Care Planning Improvement Act

U.S. Representative Renee L. Ellmers (R-NC) recently became the latest member of Congress to cosponsor the Home Health Care Planning Improvement Act to allow non-physician practitioners to certify home health care services. The House version (H.R. 1342) now has a total of 193 cosponsors. The Senate version has 50 cosponsors, just one short of a majority of the Senate.

The National Association for Home Care & Hospice’s (NAHC) government affairs staff recently met with Rep. Eller’s office to discuss the legislation and thanked her for her support. NAHC’s government affairs staff continues to schedule meetings with members on both sides of the aisle in the House and Senate to build support for the legislation.

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How to Avoid Risk while Meeting Care Needs: Getting Hospice GIP and Continuous Care Right!
Web Event: Tuesday, June 21, 2016, 1:00 PM – 2:30 PM Eastern

Program Description:

As part of the Medicare participation agreement, hospices commit to having general inpatient acute care (GIP) and continuous home care (CHC) available when patient need dictates that one of these levels of care is appropriate. Research findings of the Centers for Medicare & Medicaid Services (CMS) and the Office of the Inspector General (OIG) have raised serious concerns about potential misuse of GIP — including both inappropriate use when patients are not eligible as well as instances where hospices do not have GIP available in the event that a patient may need it. These concerns have only intensified with the findings from data gathered for use in hospice payment reform efforts. CMS is also closely watching utilization trends in continuous home care (CHC). Given that CHC and GIP are under intense scrutiny, it’s time to ensure that your use of these levels of care “syncs” with the applicable regulations. As a special bonus, attendees will receive a GIP Audit Tool for use in their agency.

Program Objectives:

  • Review the CMS regulations for the GIP and CHC levels of care
  • Discuss the similarities and differences between general inpatient care and continuous care
  • Identify patient eligibility criteria and expected documentation for each level of care
  • Discuss barriers to the use of GIP and CHC
  • Share applicable scenarios for utilizing each level of care

Panel of NAHC Experts:

  • Katie Wehri, CHC, CHPC, Hospice Operations Expert, NAHC
  • Susan Strauss Garcia, Chief Compliance Officer, HopeHealth, Hyannis, MA


Live Event plus Recording: Members -$150, Non-members - $300

Recording Only: Members -$150, Non-members - $300

Click Here to Register!

Executive Director, VNAs of Vermont

The VNAs of Vermont is a membership organization of ten not-for-profit Visiting Nurse Associations in Vermont. The purpose of this organization is to increase knowledge of and to develop, improve, and expand the quality of community based home health and hospice care in Vermont. This is done through fostering collaboration and cooperation amongst member agencies and partner organizations and programs, education, leadership and public policy and advocacy.

The Executive Director is a dynamic leader who creates vision and strategically executes a plan to the membership organizations:

  • Works in conjunction with the Board of Directors to prioritize initiatives, issues, and presents to legislators or state officials
  • Possess knowledge of health care reform, accountable care organizations and health care provider systems in conjunction with home health and hospice’s role in the delivery of health services
  • Demonstrates skills as an effective and persuasive communicator, negotiator and motivator
  • Demonstrates creative thinking and innovative capabilities for and with the members.

To apply, forward cover letter, resume, and salary expectations to Sandy Rousse, VNAVT President:, or by mail: CVHHH/VNAs of VT ED Search, Attn: Sandy Rousse, CEO, 600 Granger Road, Barre, VT 05641.

Director, Hospice

OSF Healthcare “More than a Career … A Calling”

OSF Healthcare has a Director, Hospice opportunity available in our hospice division, located in Peoria, IL. The responsibilities would include supervision and operational oversight of hospice operations in all regions and for the clinical care and non-clinical services delivered to patients with twenty-four hour accountability for patient care and operations of the hospice division. Candidates must have a current RN license and bachelor’s degree. Three years of management/supervisory experience and hospice experience preferred. OSF Healthcare offers excellent benefits and compensation.

Inquires can be directed to or please apply online at

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