Home Health & Hospice

Understand how the new HHCCN and ABN forms capture essential information

Homecare Insider, December 16, 2013

On December 9 home health agencies were required to begin using the Home Health Change of Care Notice (HHCCN) and Advance Beneficiary Notice of Noncoverage (ABN) forms in place of the HHABN. Since the implementation last week, many providers continue to face confusion regarding the transition, and how information from the HHABN is being captured across the new forms.

To help clarify this confusion, we will start with Option Box 1 from the HHABN, which mandated that HHAs must provide notice prior to providing an item or service that is usually paid for by Medicare but may not be paid for in a particular case for one of four reasons:

  • It is not considered medically reasonable and necessary
  • The care is custodial
  • The individual is not confined to the home
  • The individual does not need intermittent skilled nursing care

That information now must appear on the ABN (CMS-R-131).The ABN contains three option boxes itself, but these are for purposes of Medicare billing. Option 1 allows the beneficiary to receive the items and/or services at issue and requires the notifier to submit a claim to Medicare, which will result in a payment decision that may be appealed. Option 2 allows the beneficiary to receive the noncovered items and/or services and pay for them out of pocket. No claim will be filed and Medicare will not be billed. Subsequently, no appeal rights exist. Selection of Option 3 displays that the beneficiary does not want the care in question. Like Option 2, this option does not afford appeal rights.

The reasons for providing notice that were found in Option Boxes 2 and 3 of the HHABN now require use of the HHCCN (CMS-10280):

  • HHABN Option Box 2, now for use by the HHCCN: HHAs must provide notice prior to the HHA reducing or discontinuing care listed in the beneficiary’s plan of care (POC) for administrative reasons specific to the HHA on that occasion. This notice is not optional and must given immediately on determination, or if possible, the HHA must provide enough time for the beneficiary to arrange to obtain the reduced or discontinued home health service(s) from a different HHA
  • HHABN Option Box 3, now for use by the HHCCN: HHAs must provide notice prior to the HHA reducing or discontinuing Medicare covered care listed in the POC because of a physician ordered change in the plan of care or a lack or orders to continue the care. This notice is also not optional and must be given before the actual reduction or discontinuation, if possible

As the name suggests, any change in care mandates use of the HHCCN form. HHAs are required to issue the HHCCN when a triggering event changes the beneficiary’s POC. Triggering events are reductions or terminations in care. Examples of HHCCN triggering events due to physician or provider orders include:

  • Reduction: The POC lists would care every day. The provider writes a new order to decrease wound care to every other day.
  • Termination: The POC lists wound care two times per week. The provider writes a new order to discontinue all wound care.

Examples of HHCCN triggering events due to HHA reasons include:

  • Reduction: Physical therapy (PT) services are ordered four times per week in the POC. The HHA has an unexpected staffing shortage and can only provider PT services two times per week.
  • Termination: PT services are ordered four times per week in the POC. The HHA has lost PT staff and can no longer provide any PT services.

Providers can access the HHCCN and ABN forms here.