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Regulatory Affairs Advocacy FAQs

Regulatory and clinical information is available directly to members from NAHC's team of specialists. The NAHC Regulatory staff will help cut through the red tape of Medicare surveys, denials, and assorted reimbursement problems. The NAHC Regulatory staff works closely with the Health Care Financing Administration (HCFA), surveyors, and fiscal intermediaries. Nowhere else can you talk in depth with a specialist about your specific issues and receive a customized response to your needs.

Each year the Regulatory staff drafts a regulatory agenda called NAHC's Regulatory Blueprint for Action. This document identifies important regulatory issues for home care and hospice as determined by member phone calls, letters, and personal meetings.

Here are some examples of questions members ask the NAHC Regulatory staff:

  • We received a survey deficiency from the state surveyor for making only one visit in week one, even though care began on the last day of the week - can we be cited for this? What if we disagree with the surveyor's findings?
  • Will skilled nursing, ordered twice daily, be covered indefinitely for administration of insulin if the patient is homebound, unable to self-administer, and there is no other available caregiver?
  • What medical supplies are included in the episodic payment under PPS? Are diapers and underpads included? What about insulin syringes?
  • Do outpatient therapy visits count toward the 10-visit therapy threshold?
  • When do I have to report a significant change in condition (SCIC) for PPS payment purposes?
  • Can a home health agency provide services to a patient residing in an assisted living facility?
  • If a patient under a home health plan of care arranges for therapy services on his own from a Part B provider, and we do not have an arrangement with that provider, are we responsible to the Part B provider for payment of those services?
  • Can the request for anticipated payment (RAP) be submitted on the first day of the episode, or must a billable visit be made first?
  • Must the HHA have signed verbal orders before submitting the RAP?
  • If the therapy threshold of 10-visits is projected for a patient at the start of care, but the HHA provides fewer than 10 visits, will the final payment for the episode be decreased?
  • When must the agency begin using the model home health advance beneficiary notice (HHABN)?
  • If a patient is receiving services from multiple disciplines (e.g., skilled nursing, physical therapy and home health aide), can the physical therapist perform the start of care OASIS assessment? What about the follow-up assessment?
  • Can Locator 23 or the 485 be used to document a verbal start of care or recertification?
  • What are the billing requirements for physician payment for oversight of home health and hospice plans of care?
  • Can a nurse practitioner order home health services or sign a home health plan of care?
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2010 National Association for Home Care & Hospice
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