Posted by: Robert Markette
August 21, 2006

I could not help but start the week with one more HHABN post. During a teleconference last week, I was asked about telehealth and HHABNs. I have posted on this topic previously, but the questioner raised a point that I found interesting. The question had to do with the use of option box one to notify the patient that the telehealth service is not covered by Medicare upon initiation of the non-covered care.

The issue in this case is that most providers do not charge for telehealth monitoring of home health patients. The service is provided as a free service, because it can lead to improved outcomes. (Or at least that is how it was explained to me.) Of course, this leads to a potentially confusing situation, because the HHABN using option box one is designed to explain the beneficiarys potential liability and then allow the beneficiary to either choose to pay for the care, refuse the care, or direct the agency to another insurance coverage.

The first think to keep in mind in this case is that if you do not intend to charge the beneficiary, you may estimate the beneficiarys cost at $0. CMS made that point clear in the question and answer documents they published this year.

However, the HHABN does not provide a spaces to for the beneficiary to say, Yes, I choose to receive these free services. Instead, they are left with the option of saying they choose to receive the services and will pay for them. The obvious concern is that the beneficiary will wonder why they have to complete any paperwork stating they will agree to pay for a service that they have just been told is free.

The key in this situation is explaining to the beneficiary that they will not have any costs from receiving this service. If you have estimated the charges at $0, you can point out to the beneficiary, that they are agreeing to pay $0.00 for the service. (You could then jokingly offer to send them a bill each month.) When the beneficiary asks why you are explaining to them the details of a free service and asking them to agree to pay for it, you can explain to them that CMS requires the form. You can then explain that CMS did not design the form to account for free services. If you carefully explain to the beneficiary that you do not charge for this service, but that CMS requires you to use the form, the beneficiary might better understand why you are doing this.

You will run into other situations where the HHABN does not seem to fit the circumstances. CMS limited the number of options boxes and specified what had to be included and you will have to live with that. That is why it is important that you train your staff to carefully and thoroughly explain the HHABN to the beneficiaries. When you run into situations where the HHABN does not quite fit, you will rely upon your field staff to explain the situation in a way that the beneficiary understands. Frankly, even in simple HHABN situations, your field staff will need to be able to clearly explain HHABNs, otherwise you may find yourself with a large number of unsigned HHABNs.

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