Regulations:
USE ABN DELAY TO MASTER NEW NOTICES
Published on Mon May 01, 2006
5 steps to success for phasing in the new home health advance beneficiary notice.
Just because the Centers for Medicare & Medicaid Services has put off the deadline for the HHABN doesn't mean you can take it easy this summer.
Home health agencies should use the extra three months CMS has granted in the home health advance beneficiary notice transition to get skilled on the complicated new notices and related policies and procedures, experts recommend. That way, agencies can avoid compliance problems once the new ABN deadline hits Sept. 1.
Heed these steps experts recommend to get ready for the new requirement: 1. Get specific. Under the new ABN rules, home health agencies won't have to issue a notice when they inform patients in the initial plan of care of service reductions and terminations. That means you should get used to being very specific in your care planning, advises consultant Sharon Litwin with 5 Star Consultants in Ballwin, MO.
"Put the realistic frequencies and durations on the 485, not just '2w9' or 'eval for therapy,'" Litwin urges. Using vague frequencies and durations isn't good case management anyway, but now it will trigger "way more" required ABNs under the new rules, she warns.
Example: Use specific frequencies like "SN 3w1, 2w4, 1w4" and "PT 2w6," Litwin directs. That way, agencies won't have to issue ABNs when services decrease as outlined in the initial plan of care.
Agencies would be wise to use short ranges of visits, such as two to three visits per week for x period of time, advises Regina McNamara with Kelsco Consulting Group in Cheshire, CT. "Avoid wider ranges and avoid consistently providing visits at the highest level," she adds. (For more information on using ranges to avoid unnecessary ABNs, see Eli's HCW, Vol. XV, No. 20) If your clinicians can adapt to very specific care planning now, they won't have to tackle that issue plus new ABN rules when the deadline hits this fall. 2. Communicate with the patient. The whole point of the new ABN and the lawsuit that triggered it is for home health patients to stay well informed of their care plans, McNamara notes. Agencies that started using the new ABNs early have noted some patients are confused and angry when told services are reducing or terminating.
Make clear from the beginning that services will reduce as the patient improves, "which is a good sign," McNamara counsels.
Also explain to the patient the frequency and duration of expected services, Medicare requirements, and the patient's role in her care, she adds.
"Some agencies utilize a calendar in the patient's chart as well as in the home to further reinforce the plan of care and avoid any surprises to the patient," McNamara notes. 3. Keep [...]
