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Late last week, CMS issued a new frequently asked questions on the new HHABN. The questions shed light on a number of issues as well as change the rules on when you issue an HHABN.
The biggest impact of the F.A.Q. is in the area of non-covered care. The original instructions indicated that upon an initiation, termination, or reduction of non-covered care, the beneficiary should receive an HHABN. In responding to questions on the potential for confusion created by issuing an HHABN for non-covered care, HHS revised its instructions.
According to the new F.A.Q., if care is not covered by Medicare, meaning it is paid for by another payor source and Medicare is not the secondary payor, you only issue an HHABN upon initiation of care. Let me repeat that, for care that is not covered by Medicare, you only issue an HHABN upon initiation of care. You do not need to issue an HHABN for reductions or terminations. That should alleviate some of the burden associated with HHABNs.
Of course, if Medicare coverage becomes an issue later, you will need to issue an HHABN.
Another interesting point from the F.A.Q. has to do with reductions in care after a recertification. You may recall that the original instructions stated if the plan of care calls for a reduction in services, you do not need to issue an HHABN for the reductions that occur as set forth in the original plan of care. CMS has clarified that if after recertification the plan of care calls for reductions, you have two options. You may issue an HHABN with the new plan of care and then you need not issue an HHABN for the reductions that occur as set forth in the HHABN. Your other option would be to not issue the HHABN upon recertification, but to issue an HHABN with each reduction that occurs under the plan of care.
Finally, the F.A.Q. reiterates that if you are reducing services because you do not have a physicians order for the services any longer, you should use option box 1 to explain the reduction. CMS indicated they understand the potential for confusion, but they felt it more appropriate to use option box 1, even though the beneficiary cannot actually pay you to continue providing the service if the doctor refuses to order it.
Although the rationale may not make a lot of sense, CMS has clearly stated which option box to use. Of course, with only a few weeks to go until the June 1 deadline for the new HHABN, you should expect further clarification as well as new forms from CMS.
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