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NAHC Submits Comments on Burden Reduction

Posted on Monday, August 26, 2019 12:42 PM

CMS had requested comments on their “Reducing Administrative Burden to Put Patients Over Paperwork” and this week, NAHC submitted their comments on the issue.  These are their comments:


CMS should:

  • Revise the timeframe and polices for exceptional circumstances relate to the hospice face-to-face requirements for third and later periods;
  • Permit hospices to utilize the health system’s nurse practitioners (NPs) provided that the hospice is wholly owned by the system, rather than require the NP be employed directly by the hospice (W-2 employee);
  • Establish and enforce reasonable time frames within which state survey agencies, ROs, and MACs must respond to requests for approval of an address change or establishment of a new multiple locations;
  • Provide flexibility regarding the requirement for hospices to have employment arrangements with a registered dietitian or nutritionist;
  • Create a waiver program under which hospices experiencing hardship in employing a MSW-level social worker may obtain an exception to the social work supervisory requirement;
  • Provide claims processing manual clarification related to use of Q5003 and Q5004 Codes
  • Enhance education related to hospice technical documentation requirements.

Home Health

  • Eliminate the burdensome, paperwork focused face-to-face standard that leads to erroneous claim determinations, and allow the entire medical record of the patient, not solely the physician’s record, to be considered when determining eligibility for home health services;
  • Permit either the RN or the therapist to conduct the initial and comprehensive assessment, as required by the POC, when both disciplines are ordered at the initiation of care;
  • Eliminate the requirement at §484.60(e) to provide, in writing, all treatments to be administered, and name and contact information of the clinical manager;
  • Revise the regulation to require the aide be competency evaluated in bathing through demonstration of a sponge, tub or shower and bathing and hair shampooing in sink, tub or bed, and permit home health and hospice agencies to use a “pseudo- patient” to competency evaluate the HCA for the relevant skills listed in 418.64 Core services and §484.80(b)(3);
  • Permitted HHAs to provide unlimited services under arrangements both by individuals or other agencies or organizations;
  • Align §484.100(e) with the requirements of the Health Insurance Portability and Accountability Act at §1524(b) (2). §164.524(b) (2) that provides 30 days for a health care entity to act upon on a request for a copy of the medical record. Also in accord with §164.524(c) (4).  HHAs should be allowed to charge a cost-based
  • fee for the labor to copy the record, any required supplies, and postage, if applicable;
  • Require the MA plans and their vendors implement the same burden relief strategies for contracted providers as Medicare Fee- for-Service.

Home Health and Hospice

  • Ensure comprehensive and consistent training programs are implemented for all surveyors (state and AOs) and Region Office personnel to facilitate greater consistency in Medicare certification and recertification surveys;
  • Provide education and guidance materials to all stakeholders on the coverage criteria and the coordination of services permitted under both the Medicare and Medicaid programs for dually eligible beneficiaries.

Source: NAHC

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