Home Health & Hospice Week

Look for the release of instructions soon, says CMS.

All's quiet on the ABN front, but that doesn't mean there's a truce.

Though the July 24 deadline for commenting on the revised home health advance beneficiary notice (HHABN) has passed--and at press time instructions were still pending--you can expect the feds to stick to the Sept. 1 deadline for implementing the new form.

"Who knows what's next?" allows Regina McNamara with Kelsco Consulting Group in Cheshire, CT, echoing the frustration of many home health administrators  trying to get staff up to speed on using the new forms without the benefit of a full complement of instructions.

Down to the wire: The Centers for Medicare & Medicaid Services has said that they will issue the instructions in time for agencies to meet the Sept. 1 effective date.

"We're still waiting [for more guidance], says Lois Greene of Mederi Home Health Care, with branches in Florida, Illinois and Missouri. "But we're already using the revised form."

Give Compliance Your Best Shot

Consider these three tips to ease the transition:

1. Don't let CMS confuse you. Most importantly, do not go to the Beneficiary Notices Initiative (BNI) Web page--the most logical place to find a copy of the latest revised HHABN--to get a copy of the form. Instead, aim your browser for www.cms.hhs.gov/PaperworkReductionActof1995/PRAL/list.asp#TopOfPage. If you do find yourself on the BNI Web site, ignore CMS' misinformation about a June 1 implementation date and do not download the old HHABN posted there.

2. Go the extra mile once CMS issues the final instructions. In spite of the delay in officially implementing the HHABN, you should be schooling your staff in the basics about using the revised form. "Repeating training certainly won't hurt," coaches Judy Adams of LarsonAllen in Chapel Hill, NC.

Tip: To help boost compliance, devise a cheat sheet based on the final instructions, suggests McNamara. "It's easier on staff when you give them a basic 'here's what you need to know' guide," she says.

3. Be ready for a swell in paperwork, especially if your case mix includes many "brittle" patients. "We issued four to five ABNs on one patient in the first couple of weeks," reports Greene, who implemented the form early, as CMS suggested.

A physician order change affecting frequency is all you need to trigger the ABN, she explains, a situation agencies encounter often with certain categories of patients. Most at risk for high ABN usage are patients with very severe wounds, certain pulmonary conditions and diabetes with associated complications.