Medicare Compliance & Reimbursement

Short notice on new forms won't lead to leeway, say experts.

Home health providers better be prepared to hit the ground running when the new termination notices go into effect July 1 or risk compliance trouble.
 
That's despite the fact that many HHAs have never even heard of the soon-to-be-required termination notices - forms to be given out to every patient whose services are ending. And the Centers for Medicare and Medicaid Services thus far has furnished no educational efforts on the new forms. CMS: The Form Remains The Same CMS hasn't yet finalized the forms for the two-step termination notices, because the 30-day comment period for Office of Management and Budget approval closed at the end of May.
 
But agencies can expect the final forms to remain generally unchanged from the proposed forms, CMS' Tom Kessler said in the May 25 Open Door Forum for home care providers.
 
HHAs worry they won't be able to comply with the July 1 deadline due to the time required to adapt and copy the forms, formulate policies and procedures around the notices and train staff, Mary St. Pierre with the National Association for Home Care & Hospice said in the forum.
 
"I can appreciate the lack of time," Kessler acknowledged. But the forms have been proposed since last November and CMS is moving ahead with July 1 implementation as planned, he noted.
 
Advice: Go Ahead And Print CMS' Richard Lawlor suggested that HHAs start printing the forms in advance of the July 1 implementation deadline if at all possible.
 
"A lot of agencies can prepare to pull the trigger on printing" because any changes to the forms will be minor, Lawlor added.
 
HHAs often will issue the new termination notices, which can trigger an expedited review, instead of the current practice of issuing an advance beneficiary notice, Kessler said.
 
Not so fast: As CMS has said previously, the ABN isn't likely to take effect until after the termination notice already is in place, Kessler noted.