Home Health & Hospice

Ranges and the HHABN: Not a Good Fit

Homecare Insider, March 9, 2009

Specifying a range in the frequency of visits gives a homecare agency the flexibility to ensure the appropriate level of service.  (For basics about using a range, click on — (link to article that was posted 030309).)  However, when the Home Health Advance Beneficiary Notice (HHABN) enters the mix, there can be problems.  

The final instructions for use of the HHABN in 2006 said that ranges were not permitted on the notice.  In 2008, Beacon Health contacted the Medicare Enrollment and Appeals Group, the department within the CMS that deals with the Beneficiary Notice Initiative (BNI), to confirm that instruction.  Here is the reply.  
”Our final position on this issue is that when the home health agency discusses the plan of care with the patient explaining the expected frequency of services at the start of care (for example, ‘Physical therapy (PT) 3 times per week for 2 weeks and 2 time per week for 2 weeks’) the agency would not need to give an HHABN if all goes according to the plan.  If the agency explained PT 3 times per week for 4 weeks and the plan changed after 2 weeks, so that the frequency is reduced to 2 times per week, the agency would need to give an HHABN because the plan that was discussed with the patient changed….  Although the doctors can write orders in ranges, and the plan of care can be written in ranges, the purpose of the HHABN is to inform patients of specific reductions in care.”

In other words, if the plan of care includes a range, the clinician must notify the patient in advance about how that range will be implemented.  Example:  If the order is 2 to 3 visits a week for four weeks, the therapist would tell the patient this means three visits a week for two week and two visits a week for two weeks.  It would also be important to document this notification.  If care delivery veered from that, such as decreasing to two visits after one week, HHABN Option Box 3 would be necessary.   

Food for thought:  To avoid issuing the HHABN, a clinician must notify the patient in advance of the specific plan (such as, 3 wk 2, 2 wk 2, 1 wk 1) and document that plan.  So, if the clinician knows what is planned, why not just write the order that way and eliminate the use of the range?

Do your clinicians know when to issue the HHABN?  Beacon Health’s HHABN Quick Reference, a laminated guide to the notices and when to issue each one, can help.