Home Health & Hospice Week

Putting new procedures in place for these confusing requirements may take a while.

You can't put off training on the new termination notices, even if the details aren't yet crystal clear.

So advise industry experts, who tell Eli they expect the July 1 deadline for the new two-step notices and expedited review process to hold.

"The training on these forms and processes should preferably begin now, based on a limited expectation that [the Centers for Medicare & Medicaid Services] will make additional changes," counsels consultant Judy Adams with LarsonAllen Health Care Group based in Charlotte, NC. Begin training in June, at the latest, to meet the July 1 start date, Adams cautions.

"I don't expect any last-minute changes, so it's time to comply as well and as efficiently as we can," offers Bob Wardwell with the Visiting Nurse Associations of America.

There is a whole set of processes to set up around these new notices, points out consultant Lynn Yetman with Reingruber & Co. in St. Petersburg, FL. Agencies should "be getting their ducks in a row with regard to policies, procedures and forms that they will use for their termination/expedited review notices," Yetman instructs.

Figuring out how your agency can establish a workable process for timely notice delivery is an important task to start now, Adams advises.

HHAs may want to start out now familiarizing staff with the general requirements of the new notices, suggests Chicago-based consultant Rebecca Friedman Zuber. Then they can get into the procedural specifics later as they are worked out and as CMS offers more details on the notices.

Although CMS hasn't yet set the deadline for the home health advance beneficiary notice (HHABN), training staff on the termination notices and ABNs at the same time is a good idea because they are so closely related, suggests Andrew Koski of the Home Care Association of New York State.