Compliance:
DON'T FORGET SUPPLIES ON YOUR ABNs
Published on Mon Jun 26, 2006
CMS issues new questions and answers on ABN details.
You may have overlooked an important item on your home health advance beneficiary notices--and it could land you in hot water with surveyors.
Both surveyors and regional home health intermediaries will be reviewing ABNs, the Centers for Medicare & Medicaid Services warns in its supporting statement for the new forms issued June 23. Surveyors will check for Medicare condition of participation compliance while RHHIs will check for agency financial liability.
CMS clarifies how ABNs apply to supplies furnished to home health patients in a new set of questions and answers issued with the revised ABN forms and instructions.
Do this: Home health agencies should include a "general description" of patients' supplies on the ABN, CMS instructs in one question. For example, "wound care supplies" would be sufficient and an itemized list isn't required, the Q&A says.
But when a supplies reduction occurs, agencies must include enough information so that the patient understands what's being reduced, CMS says. For example, saying you will furnish wound care supplies monthly instead of weekly would be OK. Supplies Reductions Stand Alone HHAs should issue an ABN describing supplies reductions even if the supplies are the only things being cut, CMS explains in another Q&A. For instance, if the physician reduces the patient's self-administered wound care from twice a day to once a day, the agency needs to issue the patient an ABN outlining the corresponding reduction in supplies, CMS says.
Exception: Agencies do not, however, have to use ABNs for supplies that aren't covered under the home health benefit and paid for under the prospective payment system, CMS says in another Q&A. "Issue HHABNs only for services that you are billing or rendering, not items or services that beneficiaries may permissibly obtain from other sources while under your care," the agency instructs.
The set of Q&As on supplies may leave some providers scratching their heads, predicts attorney Robert Markette Jr. with Gilliland Markette & Milligan in Indianapolis. CMS' answers seem contradictory in some places--for example, not having to name supplies specifically, but having to list reductions in supplies. "Good luck navigating that one," Markette tells Eli.
In fact, HHAs may be frustrated with the lack of specificity in many of CMS' 26 new Q&As, Markette expects. "Providers want yes-or-no answers, but CMS answers vaguely" in some areas.
Providers may also be disappointed that CMS doesn't break more new ground in the Q&As. Many of the answers reinforce previous guidance and fail to address agencies' questions on the most confusing issues, judges consultant Judy Adams with Larson-Allen in Charlotte, NC. The answers also don't address the changes in the revised ABNs, Adams notes.
And one Q&A points to the unnecessary workload the ABNs entail, Markette adds. [...]
