Home Health & Hospice Week

Your home health advance beneficiary notice of noncoverage (HHABN) form expired on Sept. 1, but that doesn't mean you have a new one to use. Despite its best efforts, the Centers for Medicare & Medicaid Services' revised Form CMS-R-296 still isn't ready for agencies to use and is "currently undergoing the final stages of the Office of Management and Budget review," CMS reported on August 27. The current HHABN's expiration date has been pushed back to accommodate the delay.

Reality: "It's not unusual to run up against delays when these documents are up for revision or reapproval," notes Chicago-based regulatory consultant Rebecca Friedman Zuber, though many agencies are tired of waiting for the revised form.

Good news: You can prepare for the new form and ensure that your agency quickly and efficiently makes the switch to the new document when it's ready for use. Here's how:

Tip #1: Test run the draft form. CMS doesn't prohibit you from implementing the new form in its draft stage, points out Judy Adams, president and CEO of Adams Home Care Consulting in Chapel Hill, N.C. "You can go ahead and use the draft form at anytime," she tells Eli.

If you put the form to work now, you'll have time to learn what new steps you must follow and train your staff to complete the form accurately. While the final approved form may look slightly different, most components will be the same.

Tip #2: Look forward to the change. No one likes having to learn a new way of performing the same work, but the new HHABN is more than just a revised form -- it's a better method of collecting patient data. "The changes are minimal and very positive," Adams says.

While you wait for the OMB to approve the revised form, there are a couple of common errors that you may be making on the existing one, according to Cahaba GBA's Sept 1. newsletter.

Problem: When you fail to complete the HHABN correctly, "it may be invalidated and the HHA, not the beneficiary, is liable for services not covered by Medicare," the newsletter stated. CMS hopes the new form will cut down on inaccuracies and confusion.

For example: The language you use on your HHABN must "be able to be understood by a layperson," Cahaba stresses. You shouldn't use abbreviations (such as SN for skilled nursing or PT for physical therapy). That's because beneficiaries must be able to use the form to make informed decisions -- which won't happen if they can't decipher your shorthand.

Cahaba also points out that when agencies fill in the blanks after "because," they must be very "clear and specific" about the reasons for a specific service. Rather than write "you have increased mobility," you could write "you can now leave your home unaided" or "you are able to receive medical care outside your home."

Coming soon: The proposed revisions to the final rule are meant to make completing the form a little easier and less redundant for agencies. The changes include:

• Removing the "Health Insurance Claim Information" (HIC) box in the Signature/Date section. Rather than list the HIC or Social Security number on the form, the revised HHABN may contain an optional patient identification area for agencies to list beneficiaries' birth dates or medical record numbers.

• Adding the Medicare telephone and TTY numbers for beneficiaries to Option Box 1. Currently, agencies must insert this information, but the revised form may remove this extra step.

Note: CMS is working with the OMB to approve the revised form and will post it -- along with revised instructions --at www.cms.hhs.gov/BNI/03_HHABN.asp.