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 putting the notices right in the admission packet, she says. "After all, discharge planning begins upon admission," Warmack tells Eli.

Providers easily can amend the form if the patient's discharge date changes, Warmack points out.

Heed these tips from the experts to help you comply with the expedited review notice deadline:

1. Keep communication flowing. Personnel within the agency must communicate about the patient's discharge date and any possible changes to it, Yetman says. McNamara advises discussing the discharge date in every case conference about the patient.

2. Know who's responsible. "If several staff members are visiting the patient, the team needs to decide who will deliver the notice and when," Mc-Namara says.

HHAs may want to tie the notice delivery to the completion of the discharge OASIS, Adams says.

3. Use reminders. Someone at your agency should be in charge of tracking patients' discharge dates and reminding visiting staff to deliver the notices.

McNamara recommends having clinicians give their reminder dates - about a week before the discharge dates - to the scheduler. The scheduler then can then put corresponding reminders on the schedule for those visits. The process should work the same as reminder dates for recertifications, she explains.

Or agencies can have their case manager or primary clinicians track the discharge dates and remind visiting staff of when to deliver the forms, Adams offers.

4. Involve patients. HHAs will reduce the number of potential expedited reviews by keeping patients in the loop on discharge plans. Discuss the discharge date, even if it's only approximate, at admission or shortly thereafter, McNamara advises. "This is simply good practice, and good patient education."

"[Involving] patients in the plans of care and discharge planning from the beginning to the end of services" is more important than ever under the expedited review process to head off reviews, Adams emphasizes.

5. Carry blank forms. In case clinicians are caught unawares by an imminent discharge, they should carry blank first-step notices with them at all times, Warmack counsels. They can quickly fill in the patient information and discharge date. "Placing the forms in admission packets, recertification packets and discharge packets should help," she says.