CMS Revises the SNF ABN
CMS Revises the SNF ABN. Is Your Facility Issuing Proper Medicare Notices?
The new survey process requires facilities to provide surveyors a list of ALL Medicare beneficiaries discharged in the last six months within the first 24 hours of survey.
It’s time to unravel the mystery and get a jump start on CMS’s newly revised Skilled Nursing Facility Advance Beneficiary Notice of Non-coverage (SNF ABN). With countless initiatives and probe audits combing through SNF Medicare claims, don’t be the low hanging fruit! Understand the requirements of the SNF ABN, as well as what’s required during survey.
Within the first 24 hours of health inspection survey, facilities must present to surveyors a worksheet that lists all residents discharged in the past 6 months from a Medicare part A covered stay who have benefit days remaining. Surveyors will randomly select a portion of the list to audit and ensure compliance. This is a big change from the old survey process, when surveyors were provided with a list of Medicare beneficiaries who requested a demand bill in the past six months. Often, facilities had no such requests, and therefore weren’t being asked for Medicare Non-Coverage Notices.
The revised entrance conference form can be found on the CMS website in the downloads section under “Quality, Safety & Oversight- Guidance to Laws & Regulations” for Nursing Homes.
CMS has released a revised Skilled Nursing Facility Advance Beneficiary Notice of Non-coverage (SNF ABN) form in addition to new instructions for completion. This revised form will be required starting on May 7, 2018. However, CMS is recommending that facilities begin using this revised ABN as soon as possible.
This revised notice has the requirements from the Denial Letters with three different options for beneficiaries to choose from. The 5 SNF Denial Letters and the Notice of Exclusion from Medicare Benefits-Skilled Nursing Facility (NEMB-SNF) will be discontinued.
Using outdated SNF ABN forms after May 7th could leave the facility financially liable. Facilities should be updating their files and processes now to be certain proper forms are in place by the May 7, 2018 effective date.
In addition to ensuring your facility is in regulatory compliance, here are some other advantages to ensuring proper notice of non-coverage:
• facility protection from financial liability,
• inform beneficiaries that services may be denied by Medicare, and
• allow beneficiaries to make informed decisions as consumers.
Don’t let this revision to the SNF ABN, intended to make the process more concise, confuse you even more.
Here are some basics on what to issue and when?
SNF ABN (CMS10055) – The revised SNF ABM (revised version mandatory 5/7/18) should be issued when the Med A stay is ending and the Medicare recipient remains in the SNF receiving custodial care. This notice is given with the Generic Notice or CMS 10123.
Notice of Medicare Non-Coverage, “Generic Notice”, (NOMNC, CMS-10123)– should be issued to all Medicare beneficiaries no later than two days before the date of the end of Medicare A/Medicare Advantage/Medicare B coverage, when the provider determines that the services no longer meet Medicare’s skilled coverage criteria. This provides the Medicare beneficiary the option of contacting the QIO and requesting an expedited review, if the beneficiary does not agree with the providers decision to discontinue covered services. The QIO must then contact the provider to inform them of the appeal and to request medical records that will be used to make that determination. At this point, the provider must then issue the Detailed Explanation of Non-Coverage (CMS-10124)- see below.
Detailed Explanation of Non-Coverage (CMS-10124)- should be issued when a Medicare recipient has request a review by the QIO after receiving the Generic Notice, as outline above. This Detailed Notice explains the details of how the determination of non-coverage was made including any specific regulations used to make such a determination.
Fee For Service Advanced Beneficiary Notice of Non-Coverage (CMS-R-131)- is given when Part B services are ending. This notice should be given with the Generic Notice (CMS-10123).
Use of the Notice of Exclusion from Medicare Benefits (NEMB SNF) is being discontinued by CMS effective May 7, 2018. Since use of the NEMB was voluntary and applied primarily to technical denials (i.e. no 3 day qualifying stay, not admitted to a SNF within 30 days of hospital discharge, no Part A benefit or for a recipient who has exhausted his/her 100 days of Medicare A benefit). CMS is continuing to encourage providers to issue the revised SNF ABN in this voluntary manor.
Please feel free to contact us if you have questions or to connect directly with one of our experts.
Sarah Ragone, MSPT, RAC-CT
VP of Reimbursement & Education