Home Health & Hospice Week

Homebound demo, NPIs also addressed in Open Door Forum.

Home care providers looking for more clarity on the newly revised home health advance beneficiary notice came away disappointed from the July 11 Open Door Forum for home care providers.

The Centers for Medicare & Medicaid Services issued the revised ABN in the June 23 Federal Register with a deadline of Sept. 1 (see Eli’s HCW, Vol. XV, No. 24).

The most notable change was the addition of an Option Box for home health agencies to use when physicians order patients’ care plan changes, CMS’ Elizabeth Carmody noted in the forum that drew 431 listeners.

The comment period for the revised ABN closes July 24, Carmody explained. “As soon as those comments can be considered, CMS will publish final detailed instructions on the HHABN in the CMS manual system,” she promised.

CMS will issue the instructions before the Sept. 1 implementation date, she pledged. CMS will also issue an MLN Matters educational article and consider other educational efforts.

Problem: Releasing final ABN instructions so close to the deadline is leaving many home care providers in a training quandary, experts note. HHAs want to finalize their ABN policies and procedures and train staff on them in advance of the deadline, but are afraid they’ll be forced to make big changes at the last minute depending on the final instructions.

Another problem: A question from one caller pointed to the difficulty many providers are having in finding the newly revised HHABN. The instructions in CMS’ listserv message tell providers to search for the Federal Register notice of the listing, then the Federal Register notice tells them to search for the document on the Paperwork Reduction Act Web site.

CMS should post the draft form on the HHABN Web site where the other ABN forms are posted (www.cms.hhs.gov/BNI/03_HHABN.asp), protests consultant Judy Adams with LarsonAllen based in Charlotte, NC.

(For copies of the new HHABN forms and instructions, email executive editor Rebecca Johnson at rebeccaj@eliresearch.com with “Revised ABN” in the subject line.)

Other than promising final instructions before the Sept. 1 deadline, CMS offered little information on the ABN in the forum that lasted less than half-an-hour.

Other issues addressed in the forum include:

• Homebound demonstration. The “Home Health Independence Demonstration,” otherwise known as the homebound demonstration, has fallen far short of its goals in attracting participants. Despite a “very massive outreach campaign,” only 51 beneficiaries have enrolled in the demonstration that Congress had capped at 15,000, CMS’ Armen Thoumaian noted in the forum.

And only 26 providers have participated in the project that started in October 2004 in Colorado, Mas-sachusetts and Missouri. When the demo began, a number of barriers including resource-intensive patients and Medicaid questions kept agencies from participating, they said (see Eli’s HCW, Vol. XIII, No. 41).

• NPIs. CMS needs to give providers some help on obtaining National Provider Identifier numbers soon, multiple callers said in the forum. CMS should back up its recent campaign to apply for NPIs with information assistance, including special Open Door Forums or similar educational opportunities, one agency maintained.

“We’re all trying to figure out what is the process to identify other NPI numbers and disseminate ours,” the caller said. A crosswalk between referring physicians’ UPINs and NPIs would help, another noted.

“We understand a need for that type of a call,” a CMS official said. The agency will issue a notice on NPIs later this year and is considering educational efforts.

• RAP billing and OASIS. HHAs don’t have to submit OASIS data before billing requests for anticipated payment (RAPs), CMS’ Wil Gehne confirmed in the forum. As the agency stated in June 20 instructions, agencies have three options and one alternative for avoiding the labor-intensive data transmission before billing (see Eli’s HCW, Vol. XV, No. 23).

• PPS Update. CMS usually updates the prospective payment system rates in a proposed rule issued around the July 4 holiday, but there’s no sign of the regulation yet this year. When the Visiting Nurse Associations of America’s Bob Wardwell asked in the forum when to expect the forthcoming regulation, CMS said it was in the clearance process and officials could not divulge any specific timeline.

Forecast: The upcoming PPS update should include minor changes to payment rates and other PPS components. A more sweeping PPS refinement proposal, which is expected to change the therapy threshold and other major payment mechanisms, is expected near the end of this year.