Home Health & Hospice Week

Sept. 1 deadline right around the corner.

As the deadline for the home health advance beneficiary notice draws near, many home health agencies are wishing they had never heard of the newly revised form.

"The HHABN process and requirements have to be among the most burdensome and potentially costly requirements--imposed by [the Centers for Medicare & Medicaid Services]," declares Regina McNamara with Kelsco Consulting Group in Cheshire, CT.

The bureaucrats who fashioned the forms should try walking in field staff's shoes for a week, maintains Cynthia Dobias, administrator of Park Ridge Home Health in Fletcher, NC. "Have them try and provide quality care while clearly explaining patient rights and responsibilities," Dobias tells Eli. That would be on top of documenting timely and correctly on an electronic system, driving up to 150 miles a day, and facing ever-increasing fuel costs, she adds.

CMS has set the new deadline for the recently revised HHABN and instructions for Sept. 1, if not sooner (see Eli's HCW, Vol. XV, No. 24). But the agency still is taking comments on the notice. CMS anticipates "prompt final approval of the new HHABN" after the comment period ends July 24, the agency says in a new notice posted on its ABN Web site.

HHABN Woes Mount

The deadline comes on the heels of the eleventh-hour delay of the June 1 deadline for the previous incarnation of the HHABN.

Held off: Park Ridge was ready to go for the June 1 date but held off implementing the new form because "I am ... not willing to confuse my patients until it's necessary," Dobias notes.

Went ahead: Mederi Home Health Care, with 23 branches in Florida, Illinois and Missouri, went ahead and implemented the last version of the new forms for the June 1 deadline, reports corporate director of clinical affairs Lois Greene. "We had already in-serviced all our employees and I did not want to stop and start again," Greene explains.

"The paperwork has definitely increased, especially combined with the expedited review forms," Greene laments.

ABNs for wound care patients are especially burdensome. "Their care never seems to stick to a frequency more than a few weeks," Greene notes. "They get better quicker and we have to reduce care, and then you need to use the forms."

The most vexing part for providers is that all of the extra work seems to be for no benefit to the patient, notes Bob Wardwell with the Visiting Nurse Associations of America. Agencies are getting ready to shoulder "the burden of delivering thousands of notices with no meaningful improvement in, well, anything," observes Wardwell, a former top CMS official.

And to make matters worse, the new requirement is hitting at a particularly inopportune time, points out consultant Lynn Yetman with Reingruber & Co. in St. Petersburg, FL. "Regular staff are on vacation, and kids are home from school," Yetman says. "This is not a good time of year to try to introduce new forms."

Expect Compliance Fumbles

Despite agencies' best efforts, the confusing rules for using the new forms combined with the significant additional burden is bound to result in compliance problems, experts predict. "Perhaps agencies will be so wildly non-compliant that CMS will need to revise the regulations," McNamara wonders.

Compliance will be especially tricky when multiple disciplines are involved in a patient's case, Yetman expects. When physical therapy completes care first, "the therapist would then be responsible for issuing the HHABN, since nursing is still providing care," she says. "Many agencies utilize contract therapists, who, in my experience, are not the best when it comes to paperwork." And that's not likely to get any better with HHABNs.

HHA management will also have to "constantly notify" PRN nursing staff when to issue forms, Yetman adds.

Voice your concerns: CMS is taking comments on the revised HHABN until July 24, CMS notes. Agencies should stress "that this meaningless activity is requiring they use precious care time to satisfy the purely bureaucratic needs," Wardwell urges. 

Note: The June 23 Federal Register notice with instructions on how to submit comments is at www.access.gpo.gov/su_docs/fedreg/a060623c.html --scroll down to the 36097--36098 entry under CMS.

The new forms, instructions, supporting statement and PRA submission statement are at www.cms.hhs.gov/PaperworkReductionActof1995/PRAL/list.asp (6/23 listing for CMS-R-296).