Patient Notices:
DON'T CONFUSE ORDERS AND CARE LEVEL FOR ABNs
Published on Tue Nov 07, 2006
One intermediary's answer to a common ABN question may surprise you.
Your responsibility to furnish home health advance beneficiary notices may be even broader than you think.
A new question and answer from regional home health intermediary Cahaba GBA spells out yet another circumstance under which an HHABN is required--and it may not be what you expect.
In its October newsletter to providers, Cahaba told agencies "that if a HHA had orders for PT 3 x wk x 3 weeks, then obtained further orders to continue 2 x wk x 1 more week, the agency would have to provide an HHABN because this was a decrease," a new Q&A in the RHHI's December newsletter to providers says.
The question: The directive confused at least one HHA. "From my previous understanding of the instructions, I would have interpreted this as not having any need for the HHABN because it was extending the care beyond the original plan rather than considering it a decrease," the agency says in the December Q&A. "Am I missing something?"
The answer: But Cahaba stands by its instruction. "The Centers for Medicare & Medicaid Services ... clarified that providers must look at the care as a 'continuum', from the patient's point of view," Cahaba says. "The patient, who is familiar with the therapist coming three times per week, is seeing the therapist less often now under the new orders. The patient must be notified of the reduction by utilizing the HHABN."
This answer is likely to surprise many providers, expects consultant Pam Warmack with Clinic Connections in Ruston, LA. "My clients have had a tremendous amount of trouble grasping this concept."
Agencies aren't likely to view this scenario as a reduction in care, notes consultant Laura Gramenelles with Simione Consultants based in Hamden, CT. "It is logical to view this scenario as an increase in ordered services," since the subsequent orders add more PT services, Gramenelles contends.
Providers "have difficulty differentiating the different rules for orders versus HHABNs," says consultant Judy Adams with LarsonAllen based in Char-lotte, NC.
"This is one of the many examples of how the home health ABN process is troubled at best," says attorney Robert Markette, Jr. with Gilliland, Markette & Milligan in Indianapolis. Look At It This Way The trick is to look at the services from the patient's point of view, Gramenelles recommends. "It is often difficult for us to separate the 'physician orders' from the level of service that the patient has been receiving," she tells Eli. But "it is how CMS views the patient expectations that drives the need for an HHABN."
Adjust your view: "In the scenario posted, the patient's care was being continued but at a reduced frequency," Warmack explains. "The clue is in the reduced frequency, [...]
