Notification to Patients re: Changes in the Plan of Care

According to Medicare at 484.10(c)(1) “The patient has the right to be informed, in advance about the care to be furnished, and of any changes in the care to be furnished.

The HHA must advise the patient in advance of the disciplines that will furnish care, and the frequency of visits proposed to be furnished.

The HHA must advise the patient in advance of any change in the plan of care before the change is made.”

Now, note it says that the HHA must “advise” (it doesn’t say in writing) However, many agencies are obtaining receipt that this information has been provided to the patient.
The interpretive guidelines tells us surveyors to interview the patient and ask how they participated in the plan of care and what they know about the care they are receiving. Depending on a patient to answer a surveyor correctly can make for a long survey, so I wanted to share what I’ve been seeing in response to this particular requirement.

Say, on admission, the RN knows that she is going to be going 3w2, 2w1 and qow 6, and that a physical therapy evaluation has been ordered. There is usually a place on the admission agreement to document that. But what about when the PT goes out and orders 3w2. Do you have documentation that the patient was notified? Or maybe you want to add aide services, or decrease or increase the nurse frequency. You probably, (hopefully) have an order to cover this change in the POC, but how to document you notified the patient prior to receiving those services is a bit more complicated.

Some agencies will use an “addendum to the admission form” noting the change and have the patient sign it, leave a copy in the home, and bring the signed copy back as a receipt. Other agencies have a “Change in POC” form that is processed in the same way. And other agencies use the good old HHABN form (Option 3) which is basically a statement that says “I understand that my physician is changing my Plan of Care.” (of course, they sign one and you file it, and leave a copy in the home)
Typically, this form is used when there is a reduction in services, but can be adapted for any change in the Plan of Care.
Personally, I like this option for 2 reasons.
1. It’s a standard CMS form you should already have and
2. Using it for these purposes further exposes your staff to the whole HHABN process and creates a level of confidence, convenience, and ultimately, compliance with the real intent of the Condition of Participation: to respect the patients right to be informed.
How is your agency dealing with the Patient’s Right to Be Informed?

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