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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 complexities 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.

 

 


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NAHC Resources

NAHC PECOS LookUp Tool Kit

Welcome to the National Association for Home Care & Hospice’s (NAHC) PECOS LookUp Tool. This tool contains the latest PECOS dataset along with the latest PECOS Pending dataset available to NAHC as supplied by CMS and will allow you to check your physician’s existence in the PECOS database.

Red Flags Rule: NAHC Guidance and Sample Policy

This document offers a detailed overview of the Red Flags rule and guidelines on the requirements for health care organizations. The overview is followed by a sample policy for home health agencies, hospices, DME suppliers, and private duty agencies to use to implement the Red Flags Rule, consistent with the FTC guidance. The currently posted effective date for compliance is June 1, 2010. However, since the date has been changed several times we recommend confirmation of implementation on the FTC website.


Physician Payment for Home Health and Hospice Services Effective January 1, 2010 - May 31, 2010

NAHC is providing the current payment rates for physician services in home health and hospice free of charge to our members.

Legislation has eliminated the proposed negative 20% update to the Medicare Physicians Fee Schedule and has provided for a zero percent update for the months of January and February, 2010. In addition, there have been revisions to the Physician's Fee Schedule Conversion Factor and Practice Expense Relative Value Units (RVUs). The fees posted below reflect those revisions and the zero percent update.

On March 2, 2010, President Obama signed into law the "Temporary Extension Act of 2010." Among other things, this law extends through March 31, 2010, the zero percent update to the Medicare Physician Fee Schedule that was in effect for claims with dates of service January 1, 2010, through February 28, 2010.

The "Continuing Extension Act of 2010" signed into law April 15 extends through May 31, 2010 the zero percent update to the Medicare physician fee schedule that was in effect for claims with dates of service from Jan. 1 through March 31, 2010.

 
 

Emergency Preparedness Resources

The packet was developed by the NAHC Emergency Preparedness Workgroup and provides tools to assist agencies, patients and their families, and agency staff develop emergency preparedness plans. The guide has been updated to include the OASIS-C.

 

The four page disaster planning guide was developed by the Department of Homeland Security to assist home health providers and their patients.

Pandemic Influenza Preparedness Resources

 

OSHA - Occupational Safety and Health Administration

 
 

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.

 


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.

 


Home Health Statute and 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.

Home Health Regulations

 
 
 
 
 
 
 
 
 
 
 
 
 

Medicare Statute

 
 
 
 
 

Local Coverage Determinations

 

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

 
 
 
 


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.

 
 
 
 


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.


OASIS-C
The Centers for Medicare & Medicaid Services (CMS) requires home health agencies to use a standardized assessment tool for all Medicare and Medicaid patients. OASIS-B1 is being replaced wiith OASIS-C effective for all assessments completed on or after January 1, 2010. The following documents have been provided by CMS to assist home health agencies transition to and train their staff in OASIS-C.

 
 

OASIS-C Training Video
OASIS-C: What You Must Know”  NAHC has arranged for a free video link to the 4 hour preconference from the NAHC Annual Meeting for all home health agencies. The presenters were the CMS contractors who were responsible for the development and testing OASIS-C. This video, with synchronized session handouts, provides: an overview of the design of OASIS-C; in-depth information on the new and revised OASIS items; conventions for accurate OASIS coding; and guidance for implementation. The content and materials presented during the conference were approved by CMS. This free four-part video can be accessed at: www.dcprovidersonline.com. The power point presentation and additional materials (including the OASIS-C data set, Conventions, and Item Usage chart) can be found by scrolling down to Program 900 at: 2009 Annual Meeting Handouts.


Consumer Assessment of Health Providers and Systems (CAHPS)
The term CAHPS refers to a comprehensive and evolving family of surveys that ask consumers and patients to evaluate the interpersonal aspects of health care. CMS and AHRQ have developed a Home Health CAHPS tool for surveying home health patients. Results of these surveys will be publicly reported on Home Health Compare in late 2010 or early 2011. Participation is voluntary, but Medicare payments may be reduced for agencies that do not participate.

 

   
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