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I have now had a chance to review the new HHABN FAQ and the new form HHABN. The FAQ contains a few clarifications.
The only new HHABN form is the Option Box 3 version. This version specifically addresses the lack of physicians orders for care. It simply states that the services which you have indicated are being reduced or terminated are being reduced or terminated because the doctor has changed the patients orders. It also explains that you cannot provide the reduced or discontinued care without a doctors order.
The FAQ resolves a few more issues. There is an interesting Q&A regarding the use of pre-printed forms for common treatment scenarios. This is going beyond the simply pre-printing forms with your agency name and contact information and CMSs information, but pre-printing forms for reductions that are routine. This allows the agency to simply provide the patient with the appropriate HHABN, with out need to fill in only a few blanks, such as patient name and information. In this discussion, CMS mentions that you can use different colored forms to differentiate between the preprinted versions. Of course, they should still be high contrast light paper and dark ink combinations.
The Q&A reiterates that an HHABN is only necessary when a reduction in care occurs.
The FAQ does spend time on wound care, supplies, and how the HHABN should be used in those situations. There are two questions regarding the inclusion of supplies on the HHABN. One question addresses the need to include supplies that are outside the home health benefit. For example, the patient obtains the supplies themselves from the pharmacy. These supplies, which the patient has no obligation to obtain from the agency, do not need to be listed on the HHABN.
However, if the supplies are provided by the agency, say for example for wound care, these supplies do need to be recorded on the HHABN. Furthermore, if the supplies are reduced, because the wound care is being reduced, the agency must issue an HHABN.
In discussing this issue, CMS is responding to a providers question. In the question, the provider asks about a reduction in wound care ordered by the doctor to the patient. The more interesting point here is that even though the doctor has informed the patient of the change in ordered care, the agency must still issue an HHABN. While I understand that the patient may not make the connection between the reduced care and the reduced supplies, it seems repetitive to have to issue an HHABN to a patient who received the ordered reduction from the doctor personally. (I know, the agency is notifying the patient of the reduction in supplies, but still. This seems like a waste of agency time and paper.)
Two more points on supplies, according the FAQ, you do not need to list the covered supplies in detail on the HHABN. At the same time, if you are issuing an HHABN upon a reduction of supplies, you must provide enough detail in the reduction HHABN to ensure the patient understands the nature of the reduction. I suppose this means you can say, do to the reduction in the frequency of your wound care, we are reducing the wound care supplies we provide you. These supplies are:.... It may not require that much, the key will be what it takes to "ensure the patient understands." One final note, if you reducing supplies as part of the normal "modality" of treatment, say for example a reduction of supplies in wound care that is normal. For example, POC orders visits for wound care and at the start includes orders for a debriding agent. As the wound heals, the debriding agent is unnecessary so the agency receive orders discontinuing the agent, but maintaining the same frequency of wound care. In this case, their is no need for an HHABN, because the change in supplies used for the same frequency of treatment is not a reduction. In other words, the frequency of visits stays the same, but the supplies used during the visit change is not a reduction. I am not sure how often this situation arises. But you should be aware of the CMSs distinction between changes in frequency of services and modality of services.
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