Exceptions to the rule: Know when to use an HHABN
For every rule, there are exceptions, and the new instructions governing the use of Home Health Advance Beneficiary Notices (HHABNs) also have their exceptions to the rule. According to the most recent postings on the Q&A section of the CMS web site, the following questions identify exceptions to the HHABN rules:
Q. Is an HHABN required when we refer/coordinate a transfer to another HHA? What about home attendants obtained through another HHA?
A. HHABNs are not required in these situations. Transfers are discussed in Section IV of the revised HHABN instructions posted on the CMS and Regional Home Health Intermediary (RHHI) web site in February. Beyond that, liability notice policy only requires that rendering or billing providers give notice.
Q. If the patient is a Medicare beneficiary and is receiving skilled services paid by Medicare, and the patient would like to pay privately for additional custodial care, what notice would we give?
A. No notice is necessary since this is considered an increase in care, which is not a triggering event.
Q. What if the patient takes a turn for the worse and his or her home health care is put on hold — the patient is not discharged, but hospitalized. This means the patient's plan of care has changed. Do we need to give an HHABN?
A. Again, HHABNs are not required when the level of care increases, or when an individual is hospitalized.
Q. What if a staff member gets sick and we are not able to get someone to the patient's home on a certain day, do we need to give an HHABN?
A. No. An HHABN is necessary in emergency or unplanned situations.
Source: Centers for Medicare & Medicaid Services, HHABN Q and As. Web site: www.cms.hhs.gov.