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.
