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
- What medical supplies are included in the episodic payment
under PPS? Are diapers and underpads included? What about insulin
- Do outpatient therapy visits count toward the 10-visit therapy
- 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
- Must the HHA have signed verbal orders before submitting
- 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?