CMS’ Requirements for NPs Ordering Home Health Services Raises Concern

NAHC has major concerns it will be addressing with CMS On April 27, 2022, the Centers for Medicare & Medicaid Services (CMS) issued Change Request 12615 to clarify requirements for allowed practitioners under the home health benefit. In the “Background” section of the transmittal, CMS states that nurse practitioners and clinical nurse specialists acting as…

Private Duty Home Care Deserves Provider Relief

The CARES Act Provider Relief Fund has been a lifesaver to thousands of health care providers across the country. Through the fund distributions, the Department of Health and Human Services (HHS) has been able to stabilize access to care during the Public Health Emergency and help preserve the health care infrastructure for the post-pandemic future. We very much appreciate Congressional action creating the fund and the swift actions taken by HHS to prioritize the distribution of the funds.

The National Association for Home Care & Hospice strongly believes direct relief funds should be provided to personal care home care providers, and we are advocating directly to congressional leadership on this issue.

NAHC firmly believes Congress must take immediate steps to provide funds to an essential part of our health care system that, to date, has not received this crucial support. Home care companies that serve millions of Americans with vital personal health care supports, such as assistance with the administration of prescribed medications, exercise programs that maintain and improve functional capabilities, hygiene, feeding, and numerous Activities of Daily Living (ADLs) are a core part of community-based health care. These services, and the dedicated caregivers that provide them, have been uniformly recognized as essential health care providers by state and federal policymakers. However, the companies that provide this care have not received any Provider Relief Fund support since the creation of the Fund, except where those companies bill Medicare and/or Medicaid.

The companies that have been left out so far do participate in many government health programs, such as the Veterans Administration and the Administration on Aging, along with providing services funded by long term care insurance and private payment from their patients. It is estimated that they serve several million senior citizens and persons with disabilities each year, avoiding the need for high-cost institutional care. We need these companies to be operating today and tomorrow to meet the needs of our growing aged population.

Support from the Provider Relief Fund would be consistent with other distributions that have occurred so far. These include distributions to home care agencies that provide this same care through Medicaid, assisted living facilities, and behavioral health providers. Similarly, HHS has provided funding supports beyond Medicare and Medicaid providers to dentists and behavioral health providers, among others. As such, the standards and structures are in place to allow these
companies to apply for funding.

As potential legislation is drafted to provide further COVID-19 PHE relief, we request that specific PRF funding be allocated for home care providers that have not previously qualified due to their not being Medicare and/or Medicaid providers. These providers have faced the same COVID-related challenges as their Medicare and Medicaid colleagues, including workforce shortages, added expenses for personal protective equipment and cleaning supplies, and lost revenue due to added caregiver time properly performing COVID precautions and increased overtime expense.

Private duty home care providers are an essential part of allowing people to remain independent, living in their own homes, and slowing the spread of the novel coronavirus, COVID-19 and its variants.

Private duty care providers have been on the front lines of the fight against COVID-19, without the recognition and support they deserve. It is long past time to remedy that.

Private Duty Home Care Deserves Provider Relief

The CARES Act Provider Relief Fund has been a lifesaver to thousands of health care providers across the country. Through the fund distributions, the Department of Health and Human Services (HHS) has been able to stabilize access to care during the Public Health Emergency and help preserve the health care infrastructure for the post-pandemic future.…

NAHC to Congress: Extend Medicare Sequester Moratorium This Month

The National Association for Home Care & Hospice (NAHC), joined by a group of likeminded organizations, has written to congressional leaders to urge them to extend the current two percent Medicare sequester moratorium for the duration of the COVID-19 PHE, and to take action before April 1 when sequestration is scheduled to resume.

NAHC appreciates the bipartisan enactment of The Protecting Medicare and American Farmers from Sequester Cuts Act in December 2021, which extended the suspension of Medicare sequestration cuts, pursuant to The Coronavirus Aid, Relief, and Economic Security (CARES) Act. Suppressing sequestration has provided critical relief in our ongoing battle against COVID-19 and its variants, including Omicron, and enabled health care providers across the country to continue serving their patients and communities. We believe it is time for Congress to revisit the extension’s prescribed structure under which sequestration payment reductions will soon resume, and instead extend the full two percent Medicare sequester moratorium for the duration of the COVID-19 Public Health Emergency (PHE).

Since the beginning of the COVID-19 pandemic, Congress has ensured that frontline health care providers have the resources necessary to keep our doors open to care for both COVID and non-COVID patients alike. While we are encouraged that the worst days of the Omicron variant are hopefully behind us, it is also abundantly clear that daily COVID infection rates, hospitalizations, and deaths remain exceedingly high. Though we strive towards learning to live with COVID in an endemic state, it is likely premature to declare victory over the pandemic.

On February 18, President Biden renewed the COVID-19 National Emergency declaration beyond March 1, 2022, writing that “more than 900,000 people in this Nation have perished from the disease, and it is essential to continue to combat and respond to COVID-19 with the full capacity and capability of the Federal Government.” Along those lines, the U.S. Department of Health and Human Services (HHS) has recently indicated that the COVID-19 PHE will likely be renewed for an additional 90 days beyond the current expiration date in April 2022.

The Protecting Medicare and American Farmers from Sequester Cuts Act authorized a three-month delay of two percent Medicare sequester payment reductions (January 1, 2022 – March 31, 2022), followed by a three-month, one percent reduction in Medicare sequester payment reductions (April 1, 2022 – June 30, 2022). The resumption of the Medicare sequester before the end of the PHE would unnecessarily hinder our caregiving abilities, especially when the emergence of a new, potentially more dangerous and/or contagious variant continues to loom.

Consequently, NAHC believes it is vitally important to extend the current two percent Medicare sequester moratorium for the duration of the COVID-19 PHE, and to take action before April 1 when sequestration is scheduled to resume.

Full list of organizations signing the letter:

  1. National Association for Home Care & Hospice
  2. Ambulatory Surgery Center Association
  3. American Academy of Dermatology Association
  4. American Academy of Family Physicians
  5. American Academy of Ophthalmology
  6. American Academy of Physical Medicine & Rehabilitation
  7. American Association for Homecare
  8. American Association of Nurse Anesthesiology
  9. American Association of Orthopaedic Surgeons
  10. American College of Allergy, Asthma & Immunology
  11. American College of Gastroenterology
  12. American College of Osteopathic Family Physicians
  13. American College of Radiology
  14. American College of Surgeons
  15. American Medical Association
  16. American Medical Group Association
  17. American Nurses Association
  18. American Optometric Association
  19. American Physical Therapy Association
  20. American Society for Radiation Oncology
  21. American Society of Anesthesiologists
  22. American Speech-Language-Hearing Association
  23. America’s Essential Hospitals
  24. Association of American Medical Colleges
  25. Better Medicare Alliance
  26. Blue Cross Blue Shield Association
  27. Brain Injury Association of America
  28. Federation of American Hospitals
  29. Healthcare Leadership Council
  30. LeadingAge
  31. Medical Group Management Association
  32. National Association for the Support of Long Term Care
  33. Outpatient Ophthalmic Surgery Society
  34. Premier healthcare alliance
  35. Private Practice Section of the American Physical Therapy Association
  36. Vizient, Inc.

NAHC to Congress: Extend Medicare Sequester Moratorium This Month

The National Association for Home Care & Hospice (NAHC), joined by a group of likeminded organizations, has written to congressional leaders to urge them to extend the current two percent Medicare sequester moratorium for the duration of the COVID-19 PHE, and to take action before April 1 when sequestration is scheduled to resume. NAHC appreciates the…

HHS Begins Phase 4 Provider Relief Fund Distribution, Updates Reporting Requirements for Mergers

The Department of Health & Human Services (HHS) recently announced the distribution of approximately $9 billion in CARES Act Provider Relief Fund (PRF) Phase 4 payments to Medicare, Medicaid, and CHIP providers. The average payment for small providers from this distribution is $58,000, for medium providers is $289,000, and for large providers is $1.7 million. HHS has already started facilitating payments and will continue to do so in 2022.

As part of the announcement, HHS also indicated a new reporting requirement for providers involved in recent mergers or acquisitions that have received Phase 4 or American Rescue Plan (ARPA) Rural payment program funds. Specifically:

  • If the Recipient’s Phase 4/ARP Rural payment(s) exceeds $10,000, the Recipient agrees to notify HHS of a merger with or acquisition of any other healthcare provider during the Payment Received Period within the Reporting Time Period (as defined in the PRF Post Payment Notice of Reporting Requirements). Providers who report a merger/acquisition may be more likely to be audited, consistent with an overall risk-based audit strategy.”

HRSA (the HHS agency implementing the PRF program) considers changes in ownership, mergers/acquisitions, and consolidations to be reportable events under this new requirement. If a provider that received a Phase 4/ARP payment indicates when they report on the use of funds that they have undergone a merger or acquisition during the applicable Payment Received Period, this information will be a component that is factored into whether an entity is audited.

The PRF Frequently Asked Questions (FAQs) were also supplemented in conjunction with the Phase 4 distribution. The newly added items cover a wide range of topics, including mergers and acquisitions, tax credits, guidance for providers that file bankruptcy petitions, and more.

NAHC encourages our members who have received PRF or ARP Rural funds to review the FAQs and other related reporting guidance, to ensure timely and accurate compliance with all criteria. We will continue to monitor and analyze PRF modifications as they develop.

HHS Begins Phase 4 Provider Relief Fund Distribution, Updates Reporting Requirements for Mergers

The Department of Health & Human Services (HHS) recently announced the distribution of approximately $9 billion in CARES Act Provider Relief Fund (PRF) Phase 4 payments to Medicare, Medicaid, and CHIP providers. The average payment for small providers from this distribution is $58,000, for medium providers is $289,000, and for large providers is $1.7 million.…

NAHC Advocacy Win! Congress Extends Suspension of Medicare Sequestration

Last night the U.S. House of Representatives voted 384-28 to to extend the suspension of the two percent Medicare sequestration through the end of 2021. The Senate voted 90-2 to approve this measure last month, but full approval in Congress was delayed when the House went into recess. The bill now goes to the desk…

NAHC Receives Clarification on CMS Policies for Home Health Agencies

The National Association for Home Care & Hospice ( NAHC) has received additional clarification on Medicare coverage policies for home health agencies. Earlier this month NAHC reported on responses from the Centers for Medicare & Medicaid Services (CMS) on several key outstanding question. In that report NAHC noted follow-up was needed on two of CMS’…

Members of Congress Push for More HCBS Funding

With the next COVID-19 relief package currently under development and possibly coming with a significant price tag, upwards of $1.9 trillion as requested by the Biden administration, many elected officials and stakeholder groups are proposing increased funding to Medicaid home and community based services (HCBS). Similar proposals have been made in earlier versions of COVID-19…