When using frequency ranges to avoid unnecessary home health advance beneficiary notices, heed these expert tips to keep on the right side of regulators: • Keep the range small. You will have a harder time arguing that you notified patients of service reductions on the plan of care if you include a huge range in visits. "It shouldn't be 1-5 per week," warns consultant Betty Gordon with Simione Consultants in West-borough, MA. Instead, keep visit ranges down to one to two visits--for example, 1-3 or 2-4, she recommends. • Descend rather than go up and down. ABNs aren't required if "the agency follows the range down, without going back up," believes Chicago, IL-based regulatory consultant Rebecca Friedman Zuber. "If they have a range of 1-3x6 and do 3, 3, 2, 2, 3, 2, then they have not followed the range," says Zuber, who formerly headed up Illinois' state survey program for HHAs. • State frequency in weeks. Unless you furnish just a visit or two per month, you should keep your visit frequencies in weeks, Gordon counsels. Otherwise, patients may have a hard time figuring out when services will actually taper down, necessitating an ABN. • Decrease over time. Don't use the frequency range to encompass the entire care plan's visit reductions. Instead, reduce the ranges over time to reflect what will happen with services, Gordon recommends. Agencies often front-load visits, so you could state 3-5 visits for the first two weeks and 2-4 visits for subsequent weeks, Gordon gives as an example. • Document. When you use ranges, be sure to document in the clinical note why you made the number of visits you made, advises Gene Tischer with trade group Associated Home Health Industries of Florida.
The frequency must be based on the patient's condition and not the agency's convenience, experts remind providers.