Home Health & Hospice Week

Nailing down who's responsible for what is crucial to compliance.

Many home health agencies felt like a bomb landed in their laps when the expedited review notice requirements took effect July 1, but you can defuse the potential compliance hotspot with top-notch training.

Staff training is the biggest challenge for Virginia Association for Home Care members, reports VAHC's Marcia Tetterton. Very late-arriving final instructions and forms made training quite difficult, Tetterton tells Eli.

Because the Centers for Medicare & Medicaid Services still hadn't finalized the forms and instructions by mid-June, many Indiana Association for Home and Hospice Care members held off on training, says IAHHC's Jean McDonald.

The result was many HHAs that weren't ready when the July 1 deadline hit, says consultant Lynn Yetman with Reingruber & Co. in St. Petersburg, FL. A number of agencies rushed by the deadline furnished inadequate training on the forms or no training at all.

HHA staff are overwhelmed by the new requirement, adds consultant Regina McNamara with LW Consulting Home Health/Hospice Division. That means they may have failed to absorb training you've already conducted.

Whether your staff need a refresher course or training nearly from scratch, use this expert advice to tackle this challenging new regulatory requirement:

1. Understand the regulation. You can't train staff well if you don't understand the requirements yourself. Management should review the expedited review notice materials, especially the first 26 pages of CMS' transmittal to contractors, the forms and their instructions, and the questions and answers CMS has posted on the reg, recommends consultant Judy Adams with LarsonAllen Health Care Group based in Charlotte, NC. (For information on where to find these materials, see Eli's HCW, Vol. XIV, No. 23)

2. Figure out who's responsible for what. A crucial task HHAs face is determining who will be responsible for which duty related to this new requirement, warns McNamara.

Tasks agencies need to assign to specific staf-fers include: delivering and explaining the notice; obtaining the beneficiary signature on the notice; putting a copy of the notice into the patient's chart; mailing the notice if alternate delivery is appropriate; responding on time to the Quality Improvement Organization if the beneficiary elects expedited review; and generating and delivering the second-step, detailed notice for expedited review.

HHAs also should make sure a designated person is responsible for scheduling delivery of the notice, Yetman adds. Providers are likely to link delivery of the notices with completion of the discharge OASIS assessment, Adams expects.

Once you know who is supposed to be doing what, you can train staff on their duties. You must be very clear on who is responsible for which duty so no one drops the ball and fails to deliver the notice, Yetman stresses. "I would include the clinicians, the supervisors, the schedulers and the support staff," she says.

3. Write your P&P. Once you have a thorough grasp of the regulatory requirements and who is responsible for what, write your policies and procedures, counsels consultant Pam Warmack with Clinic Connections in Ruston, LA. "A thorough policy and procedure [can] guide staff in how to use the new forms," War-mack tells Eli. "Policies should be instructional."

4. Formulate training. In addition to the delegated responsibilities, staff need to know a variety of basics about the new requirement. Education should include an overview of the two forms and an explanation of when the HHA must give it out and when it does not have to, McNamara advises. Highlight the differences between the often-furnished generic notice and the much-less-used detailed notice, Adams suggests.

Include a review of the timeframes required, Adams says. And although HHAs complain that exceptions to furnishing the notice are rather cloudy, train staff on the exceptions you're sure of.

5. Time your training just right. Staff are very overwhelmed by the administrative burdens imposed in the new requirement, McNamara notes."Right now ... any in-depth, detailed training will be ineffective," she judges. "Added to their regular list of stressors is now the shortage of colleagues due to summer vacations," she continues. "The implementation of this can be quite taxing."

McNamara suggests a training session of less than one-half hour.

But staffers need to understand their responsibilities and a quickie overview won't do the job either, Warmack warns. "This training should be more than a mere five or ten minutes 'showing' them the new forms," she says.

6. Don't forget orientation. In addition to training your current staff on the requirements, you need to add a section on the new requirement to your orientation program, Warmack advises.

7. Provide handouts. Don't let your staffers leave training empty-handed. Give them an easy way to review the basics with a one-page cheat sheet to take with them, McNamara suggests.

You also need to download and customize the first-step, generic notices, Adams points out. You need to include your HHA contact information and contact info for your QIO. "Distribute a supply of the general notices to any staff that might be responsible for delivering the forms," Adams recommends.

CMS has posted a Word version of the form on its Web site to make customization easier for providers, it says in its Q&A updated July 1.

8. Remember the fifth 'W.' Besides offering information on who, what, when and where, be sure to tell your staffers why. Varied staff members will be the ones responsible for your compliance with this requirement, so securing their buy-in is essential. Explaining why you have to hand out the form - to give beneficiaries the chance to appeal the termination of their Medicare services - may help them understand why performing these duties is important, experts suggest.

Still, many HHAs are bristling at the fact that this expansive administrative burden is going into place for such a small number of beneficiaries. Around "90 percent of all home care patients will need to receive generic notices; yet only 1 to 2 percent are expected to appeal and require the detailed notice," Yetman observes.

"This is a great burden to bear for such a small portion of our patients," Warmack laments.

Note: Form descriptions and frequent questions are at www.lwconsult.com/Articles.html.