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A few weeks ago I taped a video seminar on the new HHABN form and instructions. One of the questions that came up during that presentation was whether Option Box 1 or Option Box 2 should be used when reducing or terminative services due to a lack of physician’s orders.
Because Doctor’s orders are needed as a matter of professional practice, there was an argument that Option Box 2 should be used. (The argument was basically, without a doctor’s order, a home health agency can’t provide the care regardless of whether the desired care would be covered or not and, therefore, this was a decision related to professional practice limitations and unrelated to Medicare coverage.)
We discussed this issue at length before taping and, in my opinion, explained the rationale for each option. CMS has since indicated in a Q&A that it feels Option Box 1 is appropriate whenever you are reducing or terminating services due to a lack of doctor’s orders.
CMS’s rationale is that doctor’s orders are required for coverage under Medicare. Therefore, if you no longer have Doctor’s orders, your decision to terminate is related to Medicare coverage. Based upon this “clarification” from CMS, it is probably a good idea to use Option Box 1 in this situation.
During this conference call, CMS cautioned providers that some changes may be made to the HHABN form. Although any potential changes were described as minor, CMS noted that providers printing the HHABNs in bulk may end up needing to reprint the HHABNs with the revisions.
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