VA Updates Community Cares Contracts

by Kristin Rowan | Jan 23, 2026 | Admin, CMS, Regulatory

by Kristin Rowan, Editor

VA Issues RFP

Updates to Community Care Contracts

Some Veterans receive care from VA providers. Non-VA providers can still provide care for Veterans through a Community Care contract with the U.S. Department of Veterans Affairs (VA). In late 2025, the VA released a Request for Proposal (RFP) for new CC contracts. The new contracts are designed to substantively change non-VA provider care to Veterans.

According to the VA, the new contracts are intended to:

Increase choice through an IDIQ model that allows multiple health plans to compete to serve Veterans
Raise quality of care by requiring plans to follow broad standards of care adopted by major health systems
Improve oversight and quality of care using better data, technology, and real-time management
Add flexibility so the VA can issue competitive task orders and remove underperforming contractors

How Does This Impact Care at Home?

The primary contractor, and therefore the ones responsible for bidding and ensuring quality of care are the health plans. So, how does this change impact home care and home health providers? Here’s how:

Fast changes in network participation along with sudden shifts will inevitably come as a result of plans competing and task orders changing
Plans will need to align with VA targets, so expect waves of onboarding, recurring pushes for credentialing, and increased local networking
Because the plans will be held to quality standards, you can expect that those standards will flow through provider documentation, timeliness, claims accuracy, and EVV and FWA compliance
IDIQ is specifically designed to allow changes in the middle of care, which means the VA and health plans can add or change rules or portal, and make revisions to edit sets during the contract

Get Ahead of the Changes

Plan to make some changes before these new Community Care contracts come to your local health plans. In order to comply with the contract requirements, your credentialing packets need to be updated to include up-to-date CAQH, insurance, licenses, and compliance. This will help minimize the lag-time before getting paid.

Anticipate Expectations

The health plans will be competing for contracts, so they will expect you to compete as well. Awarded contracts will likely be fulfilled by agencies who have a high clean claim rate and quick response to edits and denials. Whatever you are using for coding, documentation, and rules need to be validated before the new care contracts start. Complete documentation will comply with the VAs focus on better data and real-time management. Make sure your team is executing precise reports; centralize your records, documentation, and audits to prove performance records and decrease issue resolution time.

Final Thoughts

Non-VA providers who want to be considered to provide care to Veterans need to show alignment with the VA’s goals to expand choice, raise quality, and increase oversight. Planning ahead by meeting those standards early will make the transition process smoother one the new contracts roll out. We will continue to provide resources and information on these Community Care contracts as they are available.

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Kristin Rowan is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news. She is also a sought-after speaker on Artificial Intelligence, Technology Adoption and Lone Worker Safety. She is available to speak at state and national conferences as well as software user-group meetings.

Kristin also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. She works with care at home software providers to create dynamic content that increases conversions for direct e-mail, social media, and websites. Connect with Kristin directly at kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2026 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

That’s a No-No

by Elizabeth E. Hogue, Esq. | Apr 24, 2025 | Admin, Hospice, Medicaid, Medicare, Medicare Advantage, Regulatory

by Elizabeth E. Hogue, Esq.

No-no # 1

“No-No” may seem like something you would say to a toddler, but there is a list of things agency owners do that they should not do. Many of these are things providers may not often consider. This article focuses on the use of private duty services by hospice and home health patients, and what hospices and home health agencies cannot do with regard to aide services.

Aide Services

Both home health and hospice services are usually intermittent and provided in patients’ homes. Patients and their families may elect to utilize the services of private duty/home care companies for additional assistance. At the same time, hospice and home health patients may receive aide services from hospices and home health agencies.

Conditions of Participation

According to Medicare Conditions of Participation (CoPs), hospice and home health aides can only provide personal care services, including bathing. Aides provided by private duty/home care companies may also provide personal care. Unlike aides provided by hospices and home health agencies, however, they can provide additional services; such as laundry, food preparation, light housekeeping, shopping, and running errands.

Private Duty Services

When patients use private duty services, they are often paying for these services out of their own pockets. Even if they have long-term care insurance, patients still bear the financial burden of paying for private duty services. Longterm care insurance often costs thousands of dollars that patients probably paid for themselves. Patients usually pay by the hour for these services.

That's a No-No

Patients may, of course, utilize private duty/home care services to perform any of the services described above. It seems, however, that hospices routinely tell patients who have private duty/home care that they will not provide aide services because private duty/home care aides are able to provide personal care for patients.

Breaking it Down

Here is an example: A hospice admitted a bedridden patient with urinary and fecal incontinence. The patient and caregiver requested aide services from the hospice five days a week to bathe him. He paid for a few hours of private duty/home care services each day. The hospice refused to provide aide services five days a week to bathe him because he had private duty/home care services. No-no!

Compelled to Provide Care

ospices must provide aide services consistent with patients’ needs related to their terminal illnesses. In the example above, the patient clearly had a need for aide services five days a week. If patients and their caregivers state that they prefer to use private caregivers for personal care, then hospices must document the refusal of hospice aide services offered, consistent with applicable standards of care. Then hospices are not required to provide aide services.

Profiteering

When hospices deny aide services that are consistent with applicable standards of care and require patients and caregivers to use private duty/home care services, hospices are shifting the cost of aide services onto patients and their families. Patients and their families may have to pay for additional private duty/home care services to meet patients’ needs. The result for hospices is that they do not incur the costs of aide services, thereby increasing their profits at the expense of patients and their families.

If hospice staff members who refuse to provide aide services to patients and require patients and their families to use private duty/home care services instead are compensated in any way based on the financial performance or profitability of the hospices, let’s hope they look good in orange jumpsuits!

Intent to Defraud

If the private duty/home care services are being paid for by any federal or state health care program; such as Medicaid, Medicaid waiver, VA, or TriCare; then both home health agencies and hospices have engaged in fraudulent conduct by shifting costs that they should have incurred onto other federal government programs.

God forbid that the hospice also owns the company from which patients receive private duty/home care services! Then hospices are limiting their costs while profiting from patients and their families.

Dig Deep and Find Your No-No's

Now is the time for all home health agencies and hospices especially to audit patients’ records to make certain that all patients have been offered services that they are required to provide. If patients and their families choose to use private duty/home care aides instead, documentation must show that they were offered the services but chose to use private duty/home care aides.

No-No's Final Thoughts

The bottom line is that hospices and home health agencies must always provide services needed by patients. Patients may choose to pay for services that are paid for by the Medicare hospice or home health benefits. Patients cannot be required to pay for services privately that hospices and home health agencies must provide. Unacceptable!

This article is the first in a series of “No-no” items for agency owners.

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Elizabeth Hogue is an attorney in private practice with extensive experience in health care. She represents clients across the U.S., including professional associations, managed care providers, hospitals, long-term care facilities, home health agencies, durable medical equipment companies, and hospices.

No portion of this material may be reproduced in any form without the advance written permission of the author.

©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

Good News for Veterans and Care at Home

by Kristin Rowan | Jan 9, 2025 | Advocacy, Hospice, Regulatory

by Kristin Rowan, Editor

Biden's Final Acts

With only a short number of days left in office, President Joe Biden has been making headlines. Not all of his final decisions have been met with absolute approval, but his latest one will make a difference for our veterans wanting Care at Home. On Thursday, January 3, 2025, President Biden signed into law the Senator Elizabeth Dole 21st Century Veterans Healthcare and Benefits Improvement Act.

The Dole Act

The Elizabeth Dole Act improves upon much of the benefits, programs, and services provided by the Department of Veterans Affairs (VA). Some of these changes include providing protections for care agreements between veterans and clinicians, modifications to educational assistance programs and benefits, expansion of the Native American Direct Loan program, increases per diem rates for veteran transitional housing, and various administrative and oversight tasks.

Elizabeth Dole Home Care Act

The Elizabeth Dole Home Care Act is a bill within the larger act specific to home- and community-based services (HCBS). The home care act aims to enhance veterans’ access to the Program of All-Inclusive Care for the Elderly (PACE) nationwide. The new law also allows the VA to increase funding for HCBS. Prior to this, the VA was able to allocate 65% of nursing home care to home care services.

Additionally, the home care bill will provide support and benefits to caregivers of some disabled veterans, start a pilot to provide non-medical supportive care at home to veterans with limited access to home health aides, and increase access to HCBS for Native American Veterans.

The Industry Responds

The National Alliance for Care at Home responded to the landmark legislation, specifically siting section 301 of the bill, known as Gerald’s Law. Gerald’s is so named for a Michigan veteran who was denied his non-service related burial and plot benefit after he died at home while under VA hospice care. Gerald’s Law requires the VA to provide a burial and funeral allowance for veterans who were receiving VA hospice care in a home or other setting outside a hospital or nursing home.

“We are deeply grateful for the bipartisan support of Gerald’s Law and its inclusion in the Dole Act. This legislation ensures that Veterans and their families can choose hospice care in the setting that best meets their needs without risking the loss of crucial burial benefits. We thank Senators Moran, Tester, and Hassan, Representatives Ciscomani, Bost, Brownley, and Takano, and many others for their leadership, as well as President Biden for signing this important bill into law.”

Dr. Steve Landers

CEO, The Alliance

HCAOA, Leading Age, National PACE Association (NPA), and many others joined the Alliance in applauding Biden for signing the bill into law. They noted that providing care at home and in the community improves the quality of life for veterans and their caregivers. HCBS also come at a much lower cost than hospital and institutional care.

HCAOA said in a statement that the bill is “…a crucial victory for both veterans and their caregivers.” The President and CEO of NPA said the bill would dramatically increase options for veterans who want to age in place and that Congress can “…easily implement PACE for hundreds of thousands of additional seniors and their families.”

The VA has found that HCBS can delay or remove the need for nursing home or assisted living admission. Care at Home also reduces the risk of preventable rehospitalizations.

Final Thoughts

Once again, it seems the world is “discovering” that which we have known for ages: Home based care is better, cheaper, and more effective than institutional care. In the last few years, doctors and hospitals have figured this out and implemented hospital at home care. Now, the VA has finally figured it out as well. When this law takes effect, we as an industry will breathe a collective sigh when our veterans see better outcomes, their caregivers are better supported, the cost for their care decreases, and especially when our veterans enjoy a better quality of life in their final days without sacrificing the benefits to which they are so richly entitled.

One small step for veterans, one giant leap for Care at Home.

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Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news .She also has a master’s degree in business administration and marketing and runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

Use of Preferred Provider Agreements

by Elizabeth E. Hogue, Esq. | May 23, 2024 | Clinical, Regulatory

by Elizabeth E. Hogue, Esq.

Preferred Provider Agreements as Referral Source

In a highly competitive marketplace, home care providers of all types, including home health agencies, hospices, private duty/home care companies and home medical equipment (HME) suppliers are looking for a “leg up,” especially for patients with certain types of payors. Providers may be able to cement important referral sources using Preferred Provider Agreements. For example, a provider may wish to approach an assisted living facility (ALF) to see if it is interested in a preferred provider relationship. If so, then management of the ALF may want to sign a Preferred Provider Agreement in order to further a relationship with this provider.

Problems with Preferred Provider Agreements

The anti-kickback statute may apply if providers involved in referral arrangements receive any type of federal or state funds, including, but not limited to, payments for services provided from Medicaid waiver programs, managed Medicaid programs, the Tri-Care Program, the VA, or any other state or federal programs. The anti-kickback statute generally says that anyone who either offers to give or actually gives anyone anything in order to induce referrals has engaged in criminal conduct. There are, however, several exceptions to this statute that may be applicable.

How to Assess Your Preferred Provider Agreements

Providers should ask two crucial questions about the application of the anti-kickback statute to referral arrangements:

Is there a kickback or rebate?
If so, is there an exception or “safe harbor” that permits the arrangement even though it would otherwise violate the statute?

kickback or rebate occurs when a provider receives referrals from another provider and something flows back to the referral source from the provider who received referrals. If there is a kickback or rebate, providers must automatically ask the second question listed above. If they fail to utilize applicable exceptions, they may miss out on useful marketing strategies that are likely to result in numerous referrals.

With regard to Preferred Provider Agreements, however, it is important to note that they can be structured so that no money or anything of value changes hands between providers and the other party involved. If so, there is no kickback or rebate.

Patient Choice

The parties to Preferred Provider Agreements must also make certain that they honor patients’ choices of providers. There are a number of sources of patients’ right to freedom of choice of providers applicable to preferred provider arrangements, including:

Court decisions or the common law says that all patients – regardless of payor source, type of care rendered, or types of providers involved – have the right to control the care they receive and who provides it.

A federal statute that guarantees all Medicare and Medicaid patients the right to freedom of choice of providers. This statute may be applicable if either party receives reimbursement from the Medicare or Medicaid Programs.

When patients express preferences for certain providers, however, their choices must be honored despite the existence of Preferred Provider Agreements. The agreement of the parties to honor patients’ choices should be included in Preferred Provider Agreements.

Final Thoughts

The market to provide services to patients in their homes is expanding, but the competition for referrals among providers seems to be extremely fierce. Providers are well advised to utilize Preferred Provider Agreements to help them to increase and/or maintain referrals in order to help ensure profitability.

No portion of this material may be reproduced in any form without the advance written permission of the author.