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Thank you to everyone who took the time to complete our recent Jimmo Implementation Council survey. We are writing to provide a summary of the results and the status of our efforts.

In summary, there is enthusiasm for staying in touch and continuing to work together to advance implementation of the Jimmo Settlement.  96% of respondents would like to see a Jimmo Council listserv; we will work to roll that out by the end of this year. We also appreciate the honesty of one respondent who noted that s/he would only read others messages, not post. We hope a listserv will elicit give-and-take, so we’ll give it a try.

We are grateful for the willingness of Council members to speak out.  25% of respondents are willing to speak to policy-makers, 23% are willing to speak to CMS, 17% to Medicare Administrative Contractors.  We also appreciated additional contact suggestions, such as the Academy of Nursing.

Responses about Jimmo education to date offered mixed results:

  • 46% of respondents were not aware of the Jimmo Education Campaign provided by CMS in 2013. 
  • Only 37% of respondents participated in the education efforts. 
  • However, 80% of respondents were aware of the Jimmo Fact Sheet released by CMS, and
  • 65% were aware that the Medicare Benefit Policy Manuals had been updated. 
  • Also interestingly, of the small percentage of respondents who use Electronic Health Record Systems, just over half use a system that allows for documentation of care to maintain a patient’s condition. 

Clearly awareness and application of the Jimmo Settlement is currently far from universal. There is more work to be done.

There is widespread agreement among respondents that further well-funded research will be key to efforts to implement the Jimmo settlement. Suggestions included pilot studies of maintenance care patients v. non-maintenance patients with similar code-demographics; and use of home health records, as home health has had the ability to identify maintenance therapy since 2011.  In addition, there is widespread concern about the understanding and application of Jimmo by Medicare Administrative Contractors. Many respondents also expressed concerns about the lack of clarity of guidelines for providers trying to document skilled maintenance care.

Future goals focused on by respondents included:

  • Going back to the Jimmo judge for reinforcement of the education component;
  • Working to get a National Coverage Determination that solidifies the Jimmo Settlement;
  • Ensuring proper Education of Medicare Administrative Contractor and other coverage decision-makers;
  • Seeking inclusion of clear provisions regarding  Jimmo compliance in the Medicare Advantage Plan Call Letter;
  • Obtaining studies regarding the value of maintenance care for patients and the long-term costs, compared to those who go without;
  • Compiling a guide for beneficiaries and practitioners to understand, insist on and follow the Jimmo settlement;
  • Providing outreach to professional associations;
  • Obtaining guidance regarding acceptable documentation, especially from CMS, that would demonstrate medical necessity for maintenance therapy services;
  • Collecting stories, stories, stories!

Finally, it was exciting to see that 96% of our respondents would like to see another in-person meeting of the Jimmo Council. We are eager to make this happen and are seeking funding to do so – hoping to reconvene in June 2016.

In the meanwhile, please stay involved.  Continue to monitor implementation of the Settlement.  Be on the lookout for areas in which the Jimmo is not being followed, and for instances in which there has been progress in Medicare coverage of skilled maintenance care. Please share these examples, stories, tips, and news with the Center for Medicare Advocacy at We will post your insights and will inform Council members about happenings related to the Jimmo litigation.

Look for ongoing updates at – and via the Jimmo Council listserve; coming soon! 

Thank you again to everyone who took time to complete our survey.

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