Home Health & Hospice Week

Regulations:

Say Goodbye To HIM 11

Multitude of Internet-only manuals take its place.

It appears the trusty Medicare Home Health Agency Manual is going the way of the dinosaur, and home health agencies that don't want to do the same had better pay attention.

The Centers for Medicare & Medicaid Services is phasing out the provider-specific, paper-based manuals in favor of eight new Internet-only manuals grouped into functional areas, CMS explains in a new "one-time notification" dated Sept. 12.

So instead of separate manuals for HHAs, skilled nursing facilities, hospitals, etc., and for carriers and intermediaries, CMS now will have eight manuals that providers must look to for subject-specific information: Pub. 100-01-Medicare General Information; Pub. 100-02-Medicare Benefit Policy; Pub. 100-03-Medicare National Coverage; Pub. 100-04-Medicare Claims Processing; Pub. 100-05-Medicare Secondary Payer; Pub. 100-06-Medicare Financial Management; Pub. 100-08-Medicare Program Integrity; and Pub. 100-09-Medicare Contractor Beneficiary.

But providers can't automatically switch to the new manuals, many of which are still under development. Instead, when CMS issues new information, it will update the Internet-only manuals and delete information from the paper-based manuals.

"We will continue this phase-out/phase-in process until all manual instructions are included in the CMS Manual System," the Internet-only manuals, CMS says on its new manual Web site. "In the meantime, you should check both sets of manuals for current policy and procedures."

Doubling HHAs' manual searches isn't going to go over well, admits Mary St. Pierre with the National Association for Home Care & Hospice. "Providers have a difficult enough time checking one place," St. Pierre says.

"It will be an annoyance to check both," agrees consultant Terri Ayer with Ayer Associates in Tucson, AZ. And it won't just be checking a paper versus online manual - it will be checking a paper manual versus eight online manuals. "Agencies will have to learn how to go to various manuals and find information," St. Pierre observes.

CMS says it is developing a crosswalk from the old to new manuals that should help providers find information. It undertook the manual revision to eliminate redundancy between manuals, it says. A switch to Internet-only manuals was inevitable, Ayer says.

In addition to the manual changes, CMS will adjust how it distributes program instructions. Currently, it uses program memoranda to issue instructions to carriers and intermediaries. After Sept. 30, it will switch to using new "one-time notifications." It will also use manual revisions, "business requirements" and "confidential requirements" to communicate changes, CMS says in its notification.

The Medicare State Operations Manual (Pub. 07) looks as though it will remain largely unchanged, switching to the Internet-only SOM (Pub. 100-07).

Editor's Note: An explanation of and links to the new manual system are at www.cms.hhs.gov/manuals/. The notification is at www.cms.gov/manuals/pm_trans/R2OTN.pdf.