Medicare Compliance & Reimbursement

Despite confusion, don't bet on extension of July 1 deadline.

In its final rule in the Nov. 26, 2004 Federal Register, the Centers for Medicare and Medicaid Services set a July 1 implementation date for the new termination notices that home health providers must furnish to each discharged patient. HHAs and hospices can expect to see CMS hold to that deadline, experts say.

Technically, providers have 30 days to submit comments based on the OMB notice in the Federal Register. But because CMS made practically no changes in response to industry comments on the final rule, don't expect CMS to make any substantive changes based on these comments either, says consultant Judy Adams with LarsonAllen Health Care Group based in Charlotte, NC.

Thus, CMS could secure OMB approval and implement the new form and process by the July 1 deadline. NAHC remains hopeful that CMS will take new comments into account, and thus warns that a pushback is possible. The association urges providers to submit relevant comments on the forms.

Editor's Note: The new forms and related documents, including instructions, are at www.cms.hhs.gov/regulations/pra/ - the two termination notices (CMS-10123-10124) are under the April 29 entry. The Federal Register notice, including instructions on submitting comments within 30 days of the notice, is at www.access.gpo.gov/su_docs/fedreg/a050429c.html.