NAHC Urges CMS to Make Sweeping Regulatory Changes as Coronavirus Hits Pandemic Status

In a letter submitted to the U.S. Centers for Medicare & Medicaid Services (CMS) on Wednesday, the National Association for Home Care & Hospice (NAHC) urged regulators to make several sweeping changes that would free up home health providers in their fight against COVID-19.

The message to CMS came shortly after the World Health Organization (WHO) officially upgraded the COVID-19 outbreak to a global pandemic and just hours after one U.S. nursing home head described the coronavirus as “an almost perfect killing machine” for the elderly.

“It is increasingly apparent that care in the home is the most prudent approach whether for purposes of isolating potentially infected individuals, providing direct virus-related care or addressing the risks of infection caused by avoidable exposure to other individuals,” the Washington, D.C.-based nonprofit group’s letter stated. “As you well know, the elderly and those with fragile health conditions are considered the highest risk members of our society.”


Within the call to action, NAHC urged CMS to provide expedited access to — and financial support for — protective gear for home-based care workers. The organization also urged CMS to take steps aimed at creating a direct connection between hospital and emergency department officials to home health agencies.

NAHC additionally called on CMS to expedite transitions of patients from skilled nursing facilities (SNFs) and other in-patient settings through clear discharge planning instruction. It also highlighted the need for priority testing of suspected at-home, isolated patients and their caregivers to avoid further spread of COVID-19.

“We have been in contact and are engaged with Congress, [CMS] and the Department of Health and Human Services (HHS) on where home care fits with the virus,” NAHC President William A. Dombi said in a video to the organization’s members. “The current state of the novel coronavirus risks in the United States requires that the entire health care community evaluate its readiness and action plans to address an emerging pandemic.”


Overall, there are now more than 1,000 cases and over 30 deaths in the U.S., with more than a dozen states declaring a state of emergency.

While NAHC urged CMS to take broad action to support home health providers, it also pushed for specific measures, many of which are practical changes industry insiders have argued for even prior to the coronavirus.

In its letter, for example, NAHC asked regulators to expand the existing “homebound” requirement, allowing providers to treat individuals with suspected COVID-19 infection or those who are at elevated risk. Home health advocates — including Sen. Susan Collins (R-Maine) — have long considered the homebound requirement to be outdated and burdensome.

“Right now under Medicare, the definition of homebound is extremely strict,” Collins told Home Health Care News last year. “It says that the patient cannot leave home without — I believe the phrase is — a considerable and taxing effort. There are other beneficiaries who could benefit from home health care if we did not apply such an onerous restriction.”

NAHC also recommended that CMS lessen Medicare’s strict face-to-face physician encounter requirements for both home health and hospice providers, allowing them to instead use telephonic and telehealth-based encounters.

Additionally, along telehealth lines, NAHC suggested that telehealth visits should count toward Medicare home health LUPA thresholds as a means to minimize exposure risk and provide adequate reimbursement to providers. Remote monitoring should likewise be reimbursable for both Medicare- and Medicaid-based home health agencies, NAHC noted.

“These providers are preparing for a potential upsurge in patients, as individuals at high risk of contracting the virus — as well as those exhibiting signs of the infection — seek care,” Dombi said.

Meanwhile, the Review Choice Demonstration (RCD) — a CMS initiative designed to curb improper billing — is currently active in Illinois, Ohio and Texas. At least until the COVID-19 scare is over, that should also be suspended, NAHC believes.

Additional recommendations included allowing non-physicians to certify home health services and — in “surge areas” — installing an abbreviated comprehensive assessment while waiving the 30-day OASIS-submission requirement.

Non-physician certification is another measure industry insiders have been pushing for prior to the COVID-19 outbreak.

“The ability for patients to gain access to home health services would be much more efficient,” LHC Group Inc. (Nasdaq: LHCG) Chairman and CEO Keith Myers told HHCN last year. “We know firsthand from experience — in markets where we have a number of nurse practitioners that are working in managed care products that are not Medicare — the early intervention of nurse practitioners in the home reduces overall health care spending.”

Across the country, there are more than 12 million people of all ages currently receiving care in the home. As that demand has skyrocketed, the supply of clinicians and caregivers has lagged behind, leaving many home health providers with extremely lean staffs.

Enacting just some of the aforementioned recommendations from NAHC would likely provide much-needed relief for home health providers, especially as hospitalized coronavirus cases trickle out of hospitals and back into the community.

“The home care community is stepping up to meet the challenges presented by this virus,” Dombi said.

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