Home Health & Hospice Week

5 steps to success for phasing in the new home health advance beneficiary notice.

Just because the Centers for Medicare & Medicaid Services has put off the deadline for the HHABN doesn't mean you can take it easy this summer.

Home health agencies should use the extra three months CMS has granted in the home health advance beneficiary notice transition to get skilled on the complicated new notices and related policies and procedures, experts recommend. That way, agencies can avoid compliance problems once the new ABN deadline hits Sept. 1.

Heed these steps experts recommend to get ready for the new requirement:

1. Get specific. Under the new ABN rules, home health agencies won't have to issue a notice when they inform patients in the initial plan of care of service reductions and terminations. That means you should get used to being very specific in your care planning, advises consultant Sharon Litwin with 5 Star Consultants in Ballwin, MO.

"Put the realistic frequencies and durations on the 485, not just '2w9' or 'eval for therapy,'" Litwin urges. Using vague frequencies and durations isn't good case management anyway, but now it will trigger "way more" required ABNs under the new rules, she warns.

Example: Use specific frequencies like "SN 3w1, 2w4, 1w4" and "PT 2w6," Litwin directs. That way, agencies won't have to issue ABNs when services decrease as outlined in the initial plan of care.

Agencies would be wise to use short ranges of visits, such as two to three visits per week for x period of time, advises Regina McNamara with Kelsco Consulting Group in Cheshire, CT. "Avoid wider ranges and avoid consistently providing visits at the highest level," she adds. (For more information on using ranges to avoid unnecessary ABNs, see Eli's HCW, Vol. XV, No. 20) If your clinicians can adapt to very specific care planning now, they won't have to tackle that issue plus new ABN rules when the deadline hits this fall.

2. Communicate with the patient. The whole point of the new ABN and the lawsuit that triggered it is for home health patients to stay well informed of their care plans, McNamara notes. Agencies that started using the new ABNs early have noted some patients are confused and angry when told services are reducing or terminating.

Make clear from the beginning that services will reduce as the patient improves, "which is a good sign," McNamara counsels.

Also explain to the patient the frequency and duration of expected services, Medicare requirements, and the patient's role in her care, she adds.

"Some agencies utilize a calendar in the patient's chart as well as in the home to further reinforce the plan of care and avoid any surprises to the patient," McNamara notes.

3. Keep up to date. CMS says it may issue revised instructions and forms before the new deadline, based on comments it has received on the notices. And a new question-and-answer set is due out any day.

Designate a person to check frequently for updates on the new ABNs, recommends consultant Lynn Yetman with Reingruber & Co. in St. Petersburg, FL. Then you'll have the most recent information when it's time to finalize policies and procedures and train staff.

Providers hope CMS will issue clearer guidance on the new notices before the new implementation date, says consultant Pam Warmack with Clinic Connections in Ruston, LA. "The instructions regarding the revised HHABN are very confusing," Warmack notes.

4. ID trouble spots. Figure out now areas where your policies, procedures and training need to be very clear, before they cause compliance problems.

One confusing area is when to give ABNs for reducing services, Warmack says. Another is the difference between ABNs and expedited determination notices, McNamara adds. Watch for future guidance from CMS on these trouble spots and stress them in your training sessions.

5. Train your staff. "Agencies should take this extra time to begin training, training, and training staff on how to apply the HHABN when the September deadline arrives," Warmack quips. Have staff apply ABN rules to real-life examples and patient scenarios to understand how the new rules work, she recommends.

Timing your training sessions may be tricky. You'll want to have the latest CMS guidance on the forms, not to mention the final implementation date. But you also want to give your staff plenty of practice in getting to know the new requirements. Multiple ongoing sessions may be the best option, experts say.