Home Health & Hospice Week

Use these 5 tips to deliver your mandatory notices before it's too late.

If you fail to deliver expedited review notices to patients at least two days prior to their discharge, you're leaving yourself wide open to regulatory trouble.

The Centers for Medicare & Medicaid Services started requiring home health agencies and hospices to furnish expedited review notices to patients July 1 (see Eli's HCW, Vol. XIV, No. 23). When a patient's Medicare-covered services end, HHAs must deliver the simple, first-step notices that detail the patient's discharge date.

Don't fall behind: Because CMS implemented the requirement in a rush, the agency conceded that it would cut providers some slack on the notices at first. But that grace period won't last long and agencies should make sure they are compliant as soon as possible, experts warn.

One of the most challenging requirements of the expedited review notices is the timeframe. Regula-tions require HHAs to deliver the notices at least two days before the patient's discharge date.

"Agencies are going to have a very difficult time delivering these notices exactly two days prior to discharge," notes consultant Lynn Yetman with Reingruber & Co. in St. Petersburg, FL.

But "it is very important that staff deliver the generic notices no later than two days prior to discharge," stresses consultant Regina McNamara with LW Consulting Home Health and Hospice Division in Harrisburg, PA. "It is a matter of organization, teamwork, communication and good planning."

Besides ensuring regulatory compliance, timely delivery of the expedited review notices will cut down on the actual reviews HHAs must undergo, predicts consultant Judy Adams with LarsonAllen Health Care Group based in Charlotte, NC. And that's good news because expedited reviews give agencies a mountain of work to do in a tremendously tight timeframe of a few hours (see Eli's HCW, Vol. XIII, No. 43). The Earlier, The Better on Delivery HHAs should always plan for discharge right from the start of patients' care, experts note. But under the prospective payment system and the expedited review notice rules, doing so is more important than ever.

"All HHAs should be looking at a process that expands upon the theme that discharge planning begins at the time of admission," Adams says.

It's better "to deliver this notice too early rather than too late," McNamara adds.

While the regulation requires delivery of the notice at least two days prior to discharge, there is no limit on how early agencies can deliver them, points out consultant Pam Warmack with Clinic Connections in Ruston, LA.

Try this: McNamara and Yetman suggest furnishing the notices about a week before discharge. Adams recommends that HHAs should furnish the notices as soon as they have a realistic discharge date for the patient.

Most of the agencies Warmack works with are [...]