Home Health & Hospice Week

Regulations:

2-SHEET EXPEDITED REVIEW NOTICE OK, CMS SAYS

But exception applies only under certain circumstances.

New information about the expedited review notice requirement continues to flow, and the latest wave may make your life easier.

Home health agencies and hospices may put their generic, first-step expedited review notice on two separate sheets of paper, Centers for Medicare & Medicaid Services' Elizabeth Carmody said in a July 20 home health Open Door Forum that drew 325 callers. That's a change from CMS' earlier instructions to put the two-page form on one sheet of paper printed on the front and back.

Here's the catch: However, home care providers may use a two-sheet notice only if they are using carbonless paper for the forms, Carmody said. "The only reason we're allowing that exception is for that type of paper," she explained.

Allowing HHAs to put the notice on two sheets means beneficiaries won't have to sign multiple copies of the same notice, Carmody noted. Providers must keep the two sheets together, she instructed.

More info coming: CMS will issue this revision in writing when it releases about 40 new questions-and-answers on the requirement. The agency aims to post the new Q&As this month at
www.cms.hhs.gov/medicare/bni/.

Although the expedited review notices are mandated forms, CMS hasn't yet furnished Spanish-language versions of the form. "It's very difficult for providers to only have it accessible in one language when they're serving bilingual or trilingual populations," Heather Vasek with the Texas Association for Home Care said in the forum.

CMS can anticipate the relatively large need for Spanish-language forms and should issue English and Spanish versions simultaneously for required documents, Vasek charged.

CMS promised it is finalizing the Spanish version, which is the only non-English version of the form it plans to issue. HHAs wanting the forms translated into other languages can seek help from their CMS regional offices on the task, suggested forum moderator Dr. Richard Lawlor.
 
Other topics addressed in the forum include:
 

  • CBSAs. CMS proposes implementing the new Core-Based Statistical Area wage index designations with the new calendar year 2006 payment rates for HHAs, CMS' Randy Throndset confirmed (see Eli's HCW, Vol. XIV, No. 25). Providers that want a phased-in transition to the CBSAs should submit comments on the proposed rule to that effect, Throndset instructed. Comments on the regulation are due Sept. 6.
     
  • Bundling. CMS may make consolidated billing easier for HHAs and the other health care providers they have to work with. The agency plans to issue soon a transmittal consolidating all of its consolidated billing instructions and information, CMS' Wil Gehne said in the forum.