After April 30, 2018 it will be mandatory that all skilled nursing facilities use the new advance beneficiary notice of non-coverage form created by the CMS. The new form can be accessed here, and there is nothing stopping organizations from using it right away.
This form is to be used in instances when it is believed that Medicare Part A will not pay for services that are about to be provided. Responding in part to feedback on the old forms, the intent is to streamline the process by reducing the various letters available for SNFs to choose from. The forms for Medicare Part B services are not changing. This new form has also streamlined the process somewhat, in response to feedback on the old forms.
This new SNF ABN cannot be customized except for prefilling information in the Care, Reason Medicare May Not Pay, and Cost boxes near the top. Having documents prepared for common situations can save you some time, but it is important to ensure that what you have filled in accurately represents the situation the patient is in.
The sooner you’re using this new form the better. Have staff familiar with the form before April 30th, because after that you don’t have a choice. Start educating staff now, so your organization doesn’t suffer any shock.
Terminated Medicaid Providers
Organizations that have been terminated from treating Medicaid enrollees or receiving Medicaid payments are on notice. The CMS has been providing states with a list of these providers, under the belief that the states will no longer be providing them with Medicaid payments.
Now the OIG is creating a study to determine just how many of the terminated providers have been terminated. If you are one such organization and you have been getting payments, be prepared to have to pay back these amounts. The OIG is also examining managed care entities that may be paying for services as well, so these payments will also likely be taken back.
Finally, I’d like to highlight some tips the CMS released to avoid denials when it comes to billing tracheostomy supplies.In the linked Medicare Learning Network document the CMS states that tracheostomy supplies were billed at an incorrect rate 61.5% of the time during the 2018 reporting period. Insufficient documentation led to the improper payment 51.6% of the time. As such, the CMS wants to remind providers that documentation of the following is required when billing tracheostomy supplies:
- A Prescription;
- A Detailed Written Oder, which the supplier must receive before the claim is submitted;
- Medical Record Information;
- Correct Coding; and
- Proof of Delivery
Furthermore, code A4625 for a tracheostomy care or cleaning starter kit is not considered reasonable and necessary two weeks after an open surgical tracheostomy. Because this code is used for
These requirements are not new, but periodically, when the CMS releases a document like this, I like to highlight it to make you aware, in case you were unaware of how often improper billing was happening. Thanks for reading Reimbursement & Regulations over the past year!
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