Home Health & Hospice Week

If you're looking for ways to lighten your home health advance beneficiary notice load, be sure to look in the right direction.

Some home health agencies may not be issuing as many HH ABNs as the Centers for Medicare & Medicaid Services expects because they are trying to minimize the burden by using visit ranges on the plan of care. The thinking goes that even if you fall to the bottom of the visit range, you still don't need an HH ABN unless you go under it.

Don't fall into this compliance trap, warns attorney Robert Markette Jr. with Gilliland & Markette in Indianapolis. Section 60 of Chapter 30 of the Medicare Claims Processing Manual says although you may use a visit range on a POC, you may not use ranges on an HH ABN. CMS specified this restriction in its final ABN instructions, Markette explains.

Try this: However, if you feel the patient's plan of care is predictable, you may want to try specifying the reduction of services in the POC. If the episode follows the POC exactly, then you won't need to issue an HH ABN when the visits decrease in accordance with the plan.

"Some agencies say they have no trouble specifying the step-down of services," Markette tells Eli.

Note: You'll have to specify the reduction on a week-by-week basis, Markette cautions. "For example, 3 wk 3, 2 wk 2, 1 wk 1," he says. "You cannot, on the HHABN, list 1-3 wk 6."

But beware of creating even more work for yourself if you try this method, Markette says. "If the care does not go according to the specifics in the plan of care and services are reduced early, you will not only be issuing an HHABN, but also requesting doctors' orders," he cautions.

Bottom line: "The issue of whether or not to write the POC and HHABN that specifically is really a question of how certain you are that care will go according to this plan," Markette offers.

You also need to watch out for another common HHABN pitfall,Markette advises. You don't need an HHABN when you increase care, but you will need one when services go back down from that increase.