Home Health & Hospice Week

Late notice, overwhelmed staff head up HHAs' challenges in implementing new rule.

The new expedited review notices set off fireworks in the home health industry over the July 4th weekend, leaving many agencies yearning for independence from the taxing new paperwork burden.

Having the July 4th weekend as the implementation date for the new requirement to give every Medi-care beneficiary a Notice of Medicare Provider Non-Coverage when Medicare-covered services end made the new requirement even harder for home health agencies to implement, notes Jean McDonald with the Indiana Association for Home and Hospice Care. Holiday weekends are "hard enough to staff anyway, plus this," McDonald tells Eli.

And HHAs are juggling vacations from staff during the summer months, notes one hospital-based agency in the Cincinnati area. "Trying to get everyone trained is even more of a challenge when you have to work around vacation schedules," the HHA laments.

The Centers for Medicare & Medicaid Services made HHAs' preparation for the new regulatory requirement much more difficult by furnishing final instructions and forms at such a late date, multiple HHAs complain. "There was very little notice given from the final regs and forms for a project of this magnitude," blasts one agency in Western Kentucky. "It was ridiculous that the forms were still changing as late as June 22."

"The rules and form were very late in coming, which makes it difficult to get information out about it or to do any training on it," criticizes Neil Johnson with the Minnesota HomeCare Association.

"It would have helped to have the [Open Door] Forum longer than only 10 days in advance of the effective date," adds Casey Blumenthal with the Montana Hospital Association: An Association of Montana Health Care Providers (for Forum details, see Eli's HCW, Vol. XIV, No. 23).

On-the-ball agencies knew the requirement was coming after CMS put in place the analogous expedited review procedure for Medicare Advantage beneficiaries last year, notes Gwen Toney with the Ohio Council for Home Care (see Eli's HCW, Vol. XII, No. 20).

But despite the vigorous education campaign launched by national and state trade associations, many agencies were caught by surprise on the July 1 implementation date, industry representatives say.

"More notice would have eliminated some of the stress," says Marcia Tetterton with the Virginia Association for Home Care. "CMS did not provide ample dissemination of the form in a timely fashion, nor are they able to answer many questions regarding the appeals process." Confusion Abounds About New Notices In fact, HHAs are dissatisfied or confused by many of the answers - or lack thereof - to their questions about the new notices, industry representatives note. "It gets complicated when CMS answers questions with their usual rhetoric instead of just answering the question [...]