HHCCN Delivery

60.5 - HHCCN Delivery (Rev. 2781, Issued: 09-06-13, Effective: 12-09-13, Implementation: 12-09-13) HHAs must make every effort to ensure beneficiaries understand the entire HHCCN prior to signing it. When delivering HHCCNs, HHAs are required to explain the notice and its content, and answer beneficiary questions to the best of their ability. If abbreviations are used, the HHA should explain their meaning to the beneficiary. If the beneficiary requests additional information while completing the HHCCN, the HHA must respond timely, accurately, and completely to the information request. While in-person delivery of the HHCCN is preferable, it is not required consistent with general ABN requirements, see Medicare Claims Processing Manual, Chapter 30, §40.3.4.1. If a mode other than in person delivery is used, the HHA must adhere to the requirements under the Health Insurance Portability and Accountability Act (HIPAA). Instructions on ABN telephone notice found in §40.3.4.2 of this chapter are also applicable to HHCCNs. Delivery when change of care is due to agency administrative reasons The HHA should review the text associated with the box that was checked on the HHCCN by the HHA and verbally explain to the beneficiary that he/she may be able to obtain the same or similar care from another HHA, since coverage through Medicare is not affected. HHAs are encouraged to do as much as possible to offer ideas to beneficiaries for contacting other HHAs and must inform ordering physicians of reductions/terminations consistent with the COPs for HHAs. Delivery when change of care is due to physician orders The HHA should review the text associated with the box that was checked on the HHCCN by the HHA, and inform the beneficiary that the HHA will no longer provide certain care because the physician’s order has changed. When requested, the HHA may facilitate contact and understanding between the physician and beneficiary. The beneficiary may also seek to contact the physician directly. Retention of the HHCCN The HHA keeps a copy of the completed, signed or annotated HHCCN in the beneficiary’s record, and the beneficiary receives a copy. HHA’s may retain a scanned copy of the paper copy document in an electronic medical record if desired. The primary HHA must retain the HHCCN if a subcontractor is used. Applicable retention periods are discussed in Chapter 1 of this manual, §110. In general, this is 5 years from discharge when there are no other applicable requirements under State law. Other Considerations During Completion 1. Beneficiary Unable to Sign If the beneficiary is physically unable to sign the HHCCN and is fully capable of understanding the notice a representative is not required for signature. The beneficiary may allow the HHA to annotate the HHCCN on his/her behalf regarding this circumstance. For example, a fully cognizant beneficiary with two broken hands may allow an HHA staff person to sign and date the notice in the presence of and under the direction of the beneficiary, inserting the beneficiary’s name along with his/her own name, i.e., “John Smith, Shiny HHA, signing for Jane Doe.” Such signatures should be witnessed by a second person whenever possible. Further, the medical record should support the beneficiary’s inability to write in the applicable time period. 2. Timely Notice There are no exact time frames for HHCCN delivery. Delivery timing of the notice may sometimes occur immediately upon the HHA finding that a change in care is warranted. However, in general, HHCCN should be delivered far enough in advance of the care change so that the beneficiary may pursue alternatives to continue receiving the care noted on the HHCCN. When plans for issuance of the notice are known in advance, the HHCCN should not be issued so far in advance as to cause confusion regarding the information it conveys. Some allowance is made for “immediate” delivery prior to furnishing the care at issue when unforeseen circumstances arise such as an impending, unforeseen agency staffing shortage or a dangerous home situation. This should be avoided whenever possible, but is permissible when a situation occurs prompting an immediate determination to reduce or end services that could not have been made in advance.