The National Association for Home Care & Hospice (NAHC) has been advocating for a delay to the implementation date since thefinal rule for the HHCoPs was published. NAHC sent a letter to the acting Secretary for U.S. Department of Health & Human Services on February 2, and has since been in contact with CMS officials to request a delay. NAHC argued that six months is wholly inadequate to implement such a significant revision to the regulations. In light of the fact that it took CMS 20 years to issue a final rule for new HHCoPs and there is not a quality of care crisis in the home health care sector, it is reasonable to grant agencies additional time to come into compliance with the revisions. In addition, NAHC expressed concerns that CMS might not have the interpretive guidelines for the revised HHCoPs or surveyor training completed by the July 13 effective date.