Home Health & Hospice Week

Tip:  Wait to print new forms.

Like it or not, home health agencies will have to toe the line with home health advance beneficiary notices come September--or pay the price in financial liability and survey dings.

But after the Centers for Medicare & Medicaid Services last delay of the ABN deadline (see Eli’s HCW, Vol. XV, No. 20), home care providers are unsure of when to start preparing for the deadline.

For example, Park Ridge Home Health in Fletcher, NC printed up all of its ABN forms in advance of the June 1 deadline, reports administrator Cynthia Dobias. “Now we have to reprint again,” Dobias laments.

But thanks in part to more legal filings from plaintiffs and their attorneys at the Center for Medicare Advocacy (see Eli’s HCW, Vol. XV, No. 22), industry veterans expect the Sept. 1 deadline to stick this time. And they don’t expect CMS to implement many changes to the latest proposed forms after the comment period closes July 24.

“Perhaps there will be some last-minute sanity in how these regs are implemented,” says consultant Regina McNamara with Kelsco Consulting Group in Cheshire, CT. “But I personally will not hold my breath and will advise my clients to behave in a similar fashion.”

“I think this version is essentially the final one,” says Chicago, IL-based regulatory consultant Rebecca Friedman Zuber. “It isn’t perfect, but it is so much improved and I think everyone is tired of fighting.”

Zuber praises the change that CMS included in the last revision--an additional “Option Box” that agencies can use when a physician orders a change to the care plan. The box explains that agencies can’t furnish care without a physician’s orders (see Eli’s HCW, Vol. XV, No. 24). “Though some of the wording is still a little bit awkward, the addition of Option Box 3 is a major move forward,” Zuber judges.

With the HHABNs all but final, providers should move to implement and train staff on the new forms now to hit the ground running on the Sept. 1 deadline, experts advise. That means you have only a few short weeks to prepare.

Get your preparation in gear with these steps:

1. Review rules and new options. Make sure management understands, to the best of its ability, the new ABN requirements. “Dust off the requirements, the rules, the cheat sheets you had developed” prior to the June 1 delay, McNamara advises. Besides adding Option Box 3, the ABN rules haven’t really changed and you should be able to use the same information.

In addition to the ABN forms and instructions, you can review CMS’ two sets of questions and answers on HHABNs at www.cms.hhs.gov/BNI/03_HHABN.asp under the “Downloads” section. Warning: Don’t use the ABN forms listed on that page at press time, since they are the old versions.

Next step: After a thorough review, finalize your policies and procedures for the forms.

2. In-service staff. With your P&P ducks in a row, turn next to educating your staff on the forms they’ll be delivering and explaining. “I would begin in-services ASAP,” recommends consultant Lynn Yetman with Reingruber & Co. in St. Petersburg, FL. “Sept. 1 is right around the corner, and this time of year it is really difficult to plan meetings.”

Because things have changed little since the last aborted deadline, HHABN in-services may be more of a review for many staff than a whole new introduction, Yetman hopes.

3. Don’t print quite yet. Although observers expect the current HHABN form is all but final, waiting to print the new forms is a wise idea. “Hold off on sending anything to the printer …until we are sure CMS has made a final decision,” Yetman advises.

4. Get specific in care planning. The more vague your care planning is at the start of care, the more HHABNs will be necessary when visit frequency declines, stresses consultant Sharon Litwin with 5 Star Consultants in Ballwin, MO.

Implementing a solid case management model, where the different disciplines involved in a case work as a team to develop the care plan, will lighten agencies’ ABN load, Litwin explains. When including specific frequencies for each week, “the patients and family know on admission that their expected discharge date is planned for each discipline, and that their visits are going to decrease.”