HHABNs:
FEDS CLARIFY USE OF RANGES ON NEW NOTICES
Published on Mon Aug 21, 2006
Hint: The language you use on the official notice cannot be open ended.
Home health agencies are struggling through the first month of mandatory use of the revised home health advance beneficiary notice (HHABN)--but not without a little coaching from the feds along the way.
Change Request 5009--dated Aug. 11 and available on the HHABN Web page--is the go-to official guidance on using the new form, a spokesperson for the Centers for Medicare & Medicaid Services tells Eli. But informally, the agency is still fielding questions from home health agencies and industry representatives in ways that are mapping out the path to compliance.
Tripping point: From the start of the phase-in for the new HHABNs, agencies have been confused about how the "ranges" common to plans of care and physician orders mesh with the world of HHABNs, notes Robert Markette with Gilliland Markette & Milligan in Indianapolis.
In an informal, CMS-issued "question and answer" document obtained by Eli, the agency clarified its position this month. "As we have said before, the instructions around use of ranges on the physician orders and the POC have not changed," states CMS in the Q&A.
So HHAs are free to use the ranges in visits, supplies or services as they always have in plans of care and on physicians' orders. The trick is using that information in a way the lightens the HHABN burden while complying with CMS' firm directive that "the use of ranges is not permitted on the HHABN"
Here's how: You cannot simply lift ranges as stated from physician orders or the POC and put them verbatim onto the HHABN. But you can use ranges noted on the plan of care and physician orders to help you manage the HHABN burden.
Tip: Think about the HHABN from the perspective of the patient, suggests a CMS spokesperson: "If an order or plan of care is written in a range, what does a patient need to know to understand how many times per week they can expect to see their HHA?"
Reduce Burden With The Right Wording In the informal Q&A, CMS offers HHAs two ways to translate ranges in the POC or physician's orders into terms acceptable on HHABNs:
1. An agency can discuss a specific plan with the patient in terms that don't use ranges. For example, the agency can say, "We will visit 5 times per week for one week, 4 times per week for one week and 3 times per week for one week."
"This conversation should be documented," says CMS in the document.
Result: If care proceeds according to this plan, you won't have to issue new HHABNs when the reductions occur.
2. Alternately, an HHA can choose the specific frequency from the range that best meets the patient's needs [...]
