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Home Health & Hospice Week

Compliance:

GET TO KNOW YOUR EXPEDITED REVIEW NOTICE EXCEPTIONS

Published on Mon Jun 06, 2005

Misunderstanding this area could cost you unnecessary time and money.

Do you know just when to hand out the new expedited review notices - and when not to? If not, you could be throwing money down the drain.

Home health agencies and hospices are confused about the exceptions to the expedited review notice rule, which are scattered throughout a 77-page instruction from the Centers for Medicare & Medicaid Services to intermediaries and various other CMS documents. "Exceptions to the rule were not clear and many questions have been submitted to CMS for clarification," says Debbie Thompson with the HomeCare Association of Louisiana.

To make things worse, CMS and Quality Improvement Organizations are furnishing contradictory information on exceptions, providers report.

The National Association for Home Care & Hospice gives these pointers on when expedited review notices are NOT required:
 
  • Beneficiary requests to discontinue care;
     
  • Unsafe patient situation;
     
  • Unsafe situation for agency personnel;
     
  • Hospitalization;
     
  • Nursing home placement;
     
  • Beneficiary relocation;
     
  • Beneficiary noncompliance;
     
  • Hospice beneficiary chooses to revoke the hospice benefit; and
     
  • Beneficiary death.

    Requirements also change in two major situations, NAHC tells its members. The rule to deliver the notice to the patient two days prior to discharge doesn't apply when beneficiaries are on service fewer than two days or in cases of unanticipated changes to coverage, the association says. Unanticipated changes include a physician ordering discontinuation of covered services or a patient announcing frequent absences from home. "In these instances, the notice still would have to be delivered, but the 'two days prior' rule does not (and, logically, likely could not) apply," NAHC notes.

    And agencies may mail rather than hand-deliver notices following telephone notification of beneficiaries if coverage discontinues unexpectedly, the trade group adds.

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