Home Health & Hospice

Ranges on the Plan of Care -- Yes; on the HHABN -- No

Homecare Insider, July 27, 2009

The use of ranges in home health care has become widespread.  Some agencies use them routinely for therapy and home health aide services.  However, ranges present a big challenge for the Home Health Advance Beneficiary Notice (HHABN).  Specifically, this notice cannot report ranges.  Check the language in CMS 100-4, Chapter 30, §60.3.

The Medicare Benefit Policy Manual “allows the use of ranges when physicians write home health care orders.  An example of orders given in ranges is:  ‘therapy 2–3 times per week for 3 weeks,’ as opposed to more prescriptive orders allowing agencies less flexibility in judging patient progress (as well as making revisions in orders more likely):  ‘3 visits a week for 2 weeks, 2 visits the final week.’  Since the purpose of the HHABN is to keep the beneficiaryinformed of specific changes in the plan of care, the use of ranges on HHABNs is not permitted.“

 

In a response to Beacon Health in April 2008, a representative of the Medicare Enrollment and Appeals Group, the department within the Centers for Medicare and Medicaid Services that deals with the Beneficiary Notices Initiative, provided this guidance regarding patient notification when using a range.

“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 times 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....”

 

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 “home health aide, 2–4 wk 4,” the nurse would tell the patient this means four visits a week for one week, three visits a week for two weeks, and two visits a week for one week.  It would also be important to document this notification in the patient’s clinical record. If care delivery veered from this plan, such as decreasing to two visits in the third week, HHABN Option Box 3 would be necessary.  The question then becomes:  Once the nurse has gone through all this explanation and documentation, why not just write the order for the specific frequency and eliminate the range?  Example: “Home health aide, 4 wk 1, 3 wk 2, 2 wk 1.”

 
What’s the latest on the HHABN?  Dial in to the special audio conference on August 4 for an update.  Find moreinformation at — http://www.beaconhealth.org/icd9update.