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Note from Hugh

Medicare Weekly Update, May 27, 2008

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As reported in the March 11 Medicare Weekly Update, CMS implemented a revised ABN form effective March 3. Hospitals will be required to begin using the form no later than September 1, 2008 (either the old or the new form may be used until that date).

I have two observations about this change. First, it is disappointing that CMS has not yet released a revision to the ABN instructions in Chapter 30 of the Medicare Claims Processing Manual. While there are some instructions included in the ZIP files with the new form on the CMS Web site, those instructions do not contain nearly as much detail as Chapter 30 the Medicare Claims Processing Manual. Given the significant changes that were made to the form, the extent to which the current Medicare Claims Processing Manual instructions are still applicable is unclear.

For example, the Medicare Claims Processing Manual provides detailed instructions on how hospital staff may annotate an ABN so that it will still be valid if the beneficiary refuses to sign the ABN. However, the instructions included with the new form state that “The beneficiary or representative must sign the notice, with his or her own name . . . . The signature indicates that he or she has received the notice and understands its contents” (emphasis added). Although unclear, this seems to suggest that an annotation noting that the beneficiary refused to sign may not be sufficient to validate the new ABN form. Hopefully, CMS will release an update to Chapter 30 of the Medicare Claims Processing Manual shortly.

My second observation relates to the contents of the ZIP files posted on the CMS Web site. One of the ZIP files actually contains two different “new” ABN forms, both with the same OMB form approval number.  However, the instructions posted with the new forms state “This version of the ABN continues to combine the general ABN (ABN-G) and the laboratory ABN (ABN-L) into a single notice, with an identical OMB form number” (emphasis added). So, it is unclear why there are two different forms included in the ZIP file. Hopefully, CMS will also address this issue in the near future.

Absent further guidance from CMS, hospitals that are starting to implement the new form(s) probably need to contact their FI or MAC to determine which form should be used and to obtain guidance on which aspects of the Medicare Claims Processing Manual ABN instructions are applicable to the new form.

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