Tuesday, April 3, 2018

CMS Announces Significant Changes to SNF ABN Process


The Centers for Medicare and Medicaid Services (CMS) recently posted a MLN Matters article informing providers that they have revised the Skilled Nursing Facility Notice of Non-coverage (SNF ABN), Form CMS-10055. With this revision, CMS is discontinuing the five Skilled Nursing Facility (SNF) Denial Letters (namely, the Intermediary Determination of Noncoverage, the UR Committee Determination of Admission, the UR Committee Determination on Continued Stay, the SNF Determination on Admission and the SNF Determination on Continued Stay), and the Notice of Exclusion from Medicare Benefits (NEMB-SNF), Form CMS-20014.  CMS also notes that the Notice of Medicare Non-Coverage (NOMNC), Form CMS-10123 is not being discontinued with this revised SNF ABN. More information on the NOMNC is available here

Please note that SNFs may start to implement this new notice any time up to the implementation date of April 30, 2018.  After then, the use of the new notice is mandatory.  Please ensure that your billing staffs are aware of these changes.

Note that use of the revised SNF ABN is addressed in the requirements and interpretive guidance under F-582, Medicare/Medicaid Coverage/Liability Notice, which can be found here

Background
In order for SNFs to transfer liability to an Original Medicare beneficiary for items or services paid under Medicare Part A (SNF Prospective Payment System (PPS)), the SNF must issue a SNF ABN for:
  • An item or service that is usually paid for by Medicare, but may not be paid for in this particular instance because it is not medically reasonable and necessary, or
  • Custodial care.

Attached to the new guidance is a revised Chapter 30 of the Medicare Claims Processing Manual. This revised manual chapter provides details on SNF ABN standards and also provides information about:
  • Situations in which a SNF ABN should be given
  • Situations in which a SNF ABN Is not needed to transfer financial liability to the beneficiary
  • SNF ABN specific delivery issues
  • Special rules for SNF ABNs
  • Establishing when beneficiary is on Notice of Non-coverage

The revised notice incorporates suggestions for changes made by users of the ABN and by beneficiary advocates based on experience with the current form, refinements made to similar liability notices through consumer testing and other means, as well as related Medicare policy changes and clarifications.

SNFs will continue to use the Advance Beneficiary Notice of Non-coverage (ABN, Form CMS-R-131) for items or services that Medicare may be deny under Medicare Part B.

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