Home health agencies will recall that a revised Home Health Advance Beneficiary Notice (HHABN) was slated to go into effect on May 1, but it ran into a roadblock. This came in the form of agencies' comments on the revised form and challenges to CMS's estimate of how much of a burden it would create for providers. So CMS has gone back and revised the HHABN once more, this time with comments due on July 24, with the intent of requiring home health agencies to use only this form as of September 1. In the meantime, providers should continue to use the current HHABN. CMS is seeking Office of Management and Budget approval of its new form, in a clearance package that you can access through aahomecare (go to Advocacy and Government Relations by clicking on the button on left of homepage and see Home Health heading on the Advocacy page).
Agencies must issue an HHABN in cases where they believe that items and/or services will not be reimbursed by Medicare (Option 1), they will no longer provide care for financial or business reasons (Option 2), or a beneficiary's homecare services are being reduced as a result of physician's orders (Option 3). CMS has simplified the language on the notices, which are in both English and Spanish, and has provided a much more realistic estimate of the frequency of issuance and burden on providers. Medicare estimates that 87.9 percent of HHABNs will fall into the Option 3 category and that agencies will issue an average of 2.12 notices during an episode of care.
You may want to provide input to CMS and OMB after reviewing CMS's six-document clearance package. If you have any comments please also e-mail them to Ann Howard at ahowardaahomecare by July 17 so that we can incorporate your input into AAHomecare's comments. In addition to the OMB clearance documents, HHAs will want to review 26 new Q&As that CMS posted on its beneficiary notices website on June 20. (See Advocacy and Government Relations at aahomecare by clicking on the button on left of homepage and see Home Health heading on the Advocacy page).
American Association for Homecare
625 Slaters Lane
Suite 200
Alexandria
VA 22314
USA
(703) 836-6263.
aahomecare
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