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, [...]