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Home Health Orders for Nurse Practitioners under the Maryland Total Cost of Care (TCOC) Model

On October 10, 2019, the Center for Medicare and Medicaid Services (CMS) approved a waiver that will allow all Medicare-enrolled nurse practitioners in Maryland to certify home health services for Medicare beneficiaries beginning on January 1, 2020 as part of the Maryland TCOC Model. The Maryland TCOC Model is the first model tested by the Centers for Medicare and Medicaid Innovation (CMMI) which holds a state fully at risk for the total cost of care for Medicare beneficiaries.

CMS has instructed Maryland Medicare Administrative Contractors to begin accepting home health claims submitted by home health agencies with nurse practitioners in the attending provider field, as well as claims submitted directly by nurse practitioners for certification/re-certification and care plan oversight for home health plans of care. More information regarding the waiver can be found here and more information regarding the Maryland TCOC Model can be found here. Below is a brief primer on the components of this waiver. For any further questions, please email the AANP Federal Government Affairs department at

Who does this waiver apply to?

This waiver applies to nurse practitioners enrolled in Medicare with the Maryland Administrative Contractor (MAC) and home health agencies within Maryland on claims submitted to the Maryland MAC.

How will this waiver work in practice?

The Maryland MAC will allow home health claims (Type of Bill 032x, excluding 0322) for dates of service on or after January 1, 2020 to contain the name and National Provider Identifier (NPI) of a nurse practitioner in the Attending Provider field if a Maryland HHA submits the claim. Medicare identifies Maryland HHAs based on their CMS Certification Number beginning with 21. The Maryland MAC will also allow nurse practitioner NPIs on professional claims containing a HCPCS of G0179, G0180, G0181, or G0182.

Do I need to enroll in any other program to utilize this waiver?

Per the CMS transmittal, this waiver will apply to all Medicare-enrolled NPs in Maryland who submit claims to the Maryland MAC without the need to enroll in any other type of program.

Why is this waiver only being issued for Maryland?

Maryland has a unique arrangement with CMS where they have piloted a value-based care model which has made them the only state fully at risk for the costs of care for their Medicare beneficiaries. Under a provision of the Patient Protection and Affordable Care Act, the Secretary of Health and Human Services has broad authority to waive Medicare requirements for these types of pilot programs.

Positively, the rationale of this waiver is that the current Medicare requirements that only physicians are authorized to certify/recertify and oversee home health plans of care lead to higher total costs of care and unnecessary utilization. AANP will continue to work with CMS to remove these restrictions throughout other Medicare and Medicaid programs.