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Telemonitoring and HHABNs a clarification

Posted by: Robert Markette
August 22, 2006

Well, I have to change the answer I posted here yesterday about Telemonitoring.  Some of you may have read the e-mail NAHC sent out regarding Telemonitoring services and the use of an HHABN.  Under the original instructions and guidance, the telemonitoring service required an HHABN.  My discussion yesterday was based upon that original guidance.

However, after I received a copy of an e-mail from the National Association for Home Care (NAHC) I called Elizabeth Carmody to clarify the point.  (I must say thank you to Ms. Carmody, for taking a few minutes out of her busy day to call me back with some clarification.)  

CMS has changed its position on the use of HHABNs for telemonitoring in some circumstances.  For those of you who provide telemonitoring as a free service, there is no longer a need to provide the HHABN.  Under section 60.2 D of the new transmittal, if a service is never covered under Medicare and you are not going to charge the beneficiary for the service, no HHABN is necessary.  This means for telemonitoring, even if it is on the plan of care and integrated with the Medicare covered care, you do not need to issue an HHABN if you do not charge the beneficiary.   

However, that does not mean that all non-covered care does not require an HHABN.  If you serve dually eligible clients and the client will receive care reimbursed by Medicaid, you still need to issue an HHABN upon initiation of the care.  This is made clear in Section 60.2 D of the transmittal.  The point is that for dually eligible patients receiving Medicaid covered care or other care that is covered by insurance, but not by Medicare, the beneficiary must receive an HHABN upon initiation of care, but not for any other triggering events, until Medicare coverage again becomes an issue..




        

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