36-Month Rule’: Restrictions on Transfer of Home Health Agency Medicare Provider Numbers Pose Significant Challenges

Very quietly and without much notice by the home health industry, the U.S. Department of Health and Human Services (HHS) modified 42 CFR §424.550 in its final rule dated Nov. 10, 2009, updating the Medicare home health prospective payment system rates. Initially, very few recognized the potential implications of the new rule — but those…