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Happy HHABN day

Posted by: Robert Markette
September 01, 2006

Well today was the deadline for the new HHABN and so I felt an HHABN related post was appropriate.  In the last two weeks, I have seen a lot of discussion (or was it dismay) over the issue of ranges.  As most home health agencies are aware, the new program transmittal says that you cannot use ranges in an HHABN.  Of course, the refusal to allow ranges creates a potential for a much larger number of HHABNs.  Unfortunately, CMS has spoken and, no matter how inconvenient, ranges are not allowed in HHABNs.

There has been a number of proposals for working around this issue, because most agencies use ranges in their plans of care and because ranges would reduce the number of HHABNs an agency had to issue.  In my opinion, CMS should recognize that ranges are perfectly acceptable.  Any concern about meaningful notice being undermined by ranges is misplaced.

If a doctor can sign an order with ranges, (as CMS acknowledges), ranges should be acceptable on the POC.  I doubt physicians will sign plans of care with wide ranges, just to save an agency from issuing an HHABN.  More importantly, most state regulatory agencies limit the use of ranges.  Because an HHABN could only contain ranges that are within the limits of what is acceptable on the Plan of Care, the limitations on frequencies in a plan of care further protect beneficiaries.  The beneficiary may experience slight variations from week to week in the frequency of visits, but that really doesn’t mean the beneficiary needs a detailed written notice every time this results in a decrease in visits within an acceptable POC range.  Nevertheless, for now, don’t use ranges in your HHABN.

One of the best suggestions I have heard is to use minimum visits on the HHABN.  This creates a situation where future changes are increases.  The reasoning is that because the HHABN only lists a minimum number of visits, an HHABN does not need to be issued unless the frequency of services drop below the minimum.  I anticipate that CMS will disagree, but a number of people have suggested it to CMS.

 

         

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