I read a rather curious comment in a recent issue of Home Health Line recently. In an article on the new HHABN, there was a blurb titled "HHABNs are required for Hospices and Corfs." This statement is attributed to a CMS staffer and is based upon the June 30, 2006 notice published by CMS in this regard. I believe this staff person may have misspoken.For those of you who check in here regularly, you will recall I wrote a blurb about that notice last month.
In that post, I stated that the notice did not change much and I have repeatedly indicated that hospices did not need to worry about the new HHABN. This is why the staffers comment stood out to me.There is nothing in the notice regarding the new HHABN. The notice is quite clear that hospices are required to use ABNs, but there is nothing in the notice that would lead me to conclude the hospice is using the HHABN. In fact, the notice specifically states that the hospices are to use ABN form CMS-R-131-G (?ABN?). This is the generic ABN notice, not the revised HHABN, which is from CMSR296 (?HHABN?). The notice also offers instructions on completing the two empty boxes on the ABN. An HHABN requires additional steps to complete.
I point this out, just to clarify that according to the notice, hospice DO NO have to use the new HHABN form.
The notice also makes it clear that hospices will issue ABNs in far fewer situations than other providers. The MedLearn Matters article that was published to educate providers in regards to the notice makes the differences between hospice ABN use and HHABN use quite clear. The article ends with a clearly marked notice that hospice providers do not have to issue an ABN when care is terminated for non-coverage related reasons, such as staff safety. In other words, if you are a hospice provider and you are terminating care because your staff is not safe in the patient?s home, you do not need to issue an HHABN.
For those hospice providers who read the article and panicked, you can take a deep breath, you do not need to worry about the revised HHABN and its rules. Which makes sense, because the HHABN change is based upon a lawsuit by home health beneficiaries under the home health conditions of participation. The court?s interpretation of the home health COPs has no bearing upon how hospices operate.
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