Home Health & Hospice Week

Troubling questions bedevil termination notice, expedited review process.

Home health agencies are left with many confusing questions after reading the final rule on new termination notices and expedited reviews (see related story, p. 21).
 
For example, how will the termination notices differ from the advance beneficiary notices (ABNs) agencies already issue?
 
The Centers for Medicare & Medicaid Services has declined to spell out the differences so far, notes Bob Wardwell with the Visiting Nurse Associations of America.
 
But there are early indications of contrasts, says consultant Judy Adams with the LarsonAllen Health Care Group. HHAs will use the yet-to-be issued termination notices upon discharge, while ABNs will appear to be aimed at decisions made before admitting a patient or when reducing a patient's services, Adams notes.
 
Another question: Will there be any way for an agency to find out whether another HHA has issued a detailed, second-step termination notice to a beneficiary - and any way to see that notice? Under the new rules taking effect July 1, a second-step notice must spell out exactly why Medicare will no longer cover home care services for the patient (see Eli's HCW, Vol. XIII, No. 43, p. 339). HHAs must issue the second-step notice only when the beneficiary requests expedited review of the more generic first-step notice.
 
There will probably be no easy way for an HHA to find out if a second-step notice was issued, Wardwell expects. Only the Quality Improvement Organization will know whether a patient requested a review, and thus an agency issued a second-step notice.
 
Agencies can look up discharge information in Medicare's Direct Data Entry (DDE) system, Adams points out. But there will be no indicator of a second-step notice with the discharge, she expects.