Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare
Late January 2018, CMS posted this announcement regarding the SNFABN notice that skilled facilities must issue to Medicare beneficiaries before the facility provides:
- 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.
“CMS is releasing a newly revised Skilled Nursing Facility Advance Beneficiary Notice of Non-coverage (SNFABN) along with newly developed, concise and separate instructions for form completion. The revised SNFABN has the requirements from the Denial Letters and looks similar to the ABN with 3 different options for Original FFS Medicare beneficiaries to choose from. We will be discontinuing the 5 SNF Denial Letters and the Notice of Exclusion from Medicare Benefits – Skilled Nursing Facility (NEMB-SNF). Since the NEMB-SNF was used as a voluntary notice for care that is never covered by Medicare, we will continue to encourage providers to issue the revised SNFABN in this voluntary capacity. The revised SNFABN will be mandatory for use on May 7, 2018. During the interim, SNFs may continue to use the old version of the SNFABN, the Denial Letters or the NEMB-SNF, however, it is recommended that the revised SNFABN be used as soon as possible.
For Part A items and services: SNFs must use the newly revised SNFABN as the liability notice.
For Part B items and services: SNFs must use the Advance Beneficiary Notice of Non-coverage (ABN), Form CMS-R-131. The ABN and information on this notice can be found at https://www.cms.gov/Medicare/Medicare-General-Information/BNI/ABN.html.”
Note that I have bolded the last 2 sentences of the 1st paragraph of the CMS announcement. The revised SNFABN must be used on and after May 7, 2018 but CMS recommends that the 2017 notice be used as soon as possible.
The SNF ABN 2018 (CMS-10055) and SNF ABN Instructions both clearly show the 2018 date which is the form that you/your facility should start using as soon as possible but certainly no later than May 7, 2018.