NAHC Regulatory Affairs

Mary St. Pierre, MGA, BSN, RN Vice President, Regulatory Affairs

The Regulatory Affairs division is responsible for keeping abreast of current federal regulations and government policies that affect an agency's day to day operations as well as its long term business planning. The regulatory staff is often the first to learn of regulatory changes that have both direct and indirect effects on the home health and hospice industry. This up to the minute tracking of key regulatory events enables members to stay ahead of the curve in a rapidly changing health care environment.

Providers have access to a knowledgeable and experienced team with whom they can interact on an individual basis to assist in understanding complex regulatory mandates.

Mary K. Carr, BSN, MPH Associate Director, Regulatory Affairs

Unraveling the complicated implementation of OASIS, the home health prospective payment system, and most recently, the expedited determination process for original Medicare beneficiaries, are just a few examples of how the regulatory staff has assisted its members.

NAHC continues to work with officials at CMS to bring forth provider concerns on current and impending federal regulatory and policy issues and their impact on the home health and hospice industry.

Documents labled with a are viewable by NAHC Members only.

NAHC Resources

2008 Regulatory Blueprint for Action

Proposed Regulations
Proposed regulations are preliminary federal rules that are established by the various government agencies and published in the Federal Register.

	Hospice Conditions of Participation; Proposed rules
	Medicaid Program: Premiums and Cost Sharing
	Medicaid Program: State Flexibility for Medicaid Benefit Packages
	DME Standards

Comments on Proposed Regulations
Proposed regulations have a thirty to ninety day comment period where by all interested persons may submit written comments on the proposed rules prior to a final action.

	DME Standards
	Medicaid Benchmark Plans
	Medicaid Cost Sharing Comments

Final Regulations
After comments to a proposed rule are analyzed by the respective government agency, a final regulation is published in the Federal Register. These final regulations are what govern the implementation of Federal programs.

	Medicare Program; Home Health Prospective Payment System Refinement and Rate Update for Calendar Year 2008
	Home Health PPS: 2008 Calendar Year Refinement and Update: Corrections

Beneficiary Notices
Home health agencies are required to provide notice of Medicare non-coverage of services to beneficiaries. The following web sites and resources provide guidance needed to meet beneficiary notice requirements

	CMS Beneficiary Notice Initiative web site
	HHABN Questions and Answers September 2006
	Home Health HHABN Decision Tree for the HHABN "Final Word" Tele-conference.
	HHABN Option Box Decision Tree for Non-Coverage, Reductions, and Terminations of Medical Services.
	CMS issues the revised Home Health Advance Beneficiary Notice (HHABN) - 1/2006

Medicare Home Health Prospective Payment System (PPS)
Home health agencies are paid prospectively, based on a case-mix system, for their services. The Centers for Medicare & Medicaid Services (CMS) offers detailed information about the PPS methodology and payment calculations on its web site.

	CMS Home Health Center
	PPS 2008 Payment Calculator
	Consolidated Billing List 2008
	CMS Home Health Prospective Payment Question & Answers

Medicare Home Health Conditions of Participation and Guidance to Surveyors
In order to be certified as a provider of Medicare services home health agencies are required to comply with certain regulations. The regulations and instructions to State surveyors are available on-line.

Medicare Home Health Conditions of Participation and Guidance to Surveyors

OASIS
The Centers for Medicare & Medicaid Services (CMS) requires home health agencies to use a standardized assessment tool for all Medicare and Medicaid patients. CMS makes OASIS related web sites and on-line tools available to home health agencies

	CMS OASIS User's Manual
	OASIS User's Manual Chapter 8
	OASIS related policies and Q&A