SNF ABN Completion Tips: 4 Tips for an Error-Free Notice

By Caralyn Davis, Staff Writer - July 10, 2018

The revised Skilled Nursing Facility Advance Beneficiary Notice of Non-coverage (SNF ABN; Form CMS-10055) is “a simplified form with simplified instructions,” notes Maureen Hedrick, director of consulting services for Richter Healthcare Consultants in Twinsburg, OH. Nevertheless, mistakes can be made, so here are four tips for ensuring an error-free SNF ABN:

Don’t get creative with the form

“Liability notices can be very confusing for residents and their families. As a result, sometimes providers create their own forms in an effort to reduce anxiety levels,” points out Stacy Baker, OTR/L, RAC-CT, director of audit services for Proactive Medical Review & Consulting in Evansville, IN.

“That’s not the right approach,” she states. “You need to stick with the forms that CMS provides. I think it’s acceptable if you want to provide a typed letter with the SNF ABN. However, ultimately, the Centers for Medicare & Medicaid Services (CMS) really wants you to deliver these notices in person. Verbal explanations also will reduce a lot of havoc on the resident/representative side.”

Note: Revised Section 70.1, SNF ABN Standards, of Chapter 30, “Financial Liability Protections,” of the Medicare Claims Processing Manual states: “SNFs must not add any customizations to the notice beyond what is permitted by the accompanying SNF ABN form instructions and the guidelines published in this section.” Access this revised guidance via CMS Transmittal 4011. Access the revised SNF ABN and the SNF ABN Form Instructions here.

 

Be clear about the reason for denial

In conjunction with the revised SNF ABN, CMS has deleted its extensive list of “proper denial paragraphs” from Chapter 30 of the Medicare Claims Processing Manual. Instead, CMS offers two paragraphs of instructions and three examples in the Reason Medicare May Not Pay section of the SNF ABN Form Instructions.

“The key is to be clear and give the resident sufficient, specific information that enables them to (1) understand why Medicare may deny payment and (2) make an informed decision about which of the three options on the SNF ABN that they want to choose,” says Hedrick.

Here are the instructions straight from CMS:

 

“Reason Medicare May Not Pay” Section

 

The SNF must give the applicable Medicare coverage guideline(s) and a brief explanation of why the beneficiary’s medical needs or condition do not meet Medicare coverage guidelines. The reason must be sufficient and specific enough to enable the beneficiary to understand why Medicare may deny payment.

 

Below are examples of denial statements that explain some of the common reasons why an extended care stay or services may not be covered under Medicare. These denial statements are not mandatory language and can be modified to meet individual scenarios. The SNF may also develop language different from these examples to explain why an extended care stay, or services may not be paid for by Medicare.

 

Example 1: Beneficiary no longer requires skilled care but wants to continue residing in the SNF.

Care: Inpatient Skilled Nursing Facility Stay

Reason Medicare May Not Pay: You need only assistive or supportive care. You don’t require daily skilled care by a professional nurse or therapist. Medicare won’t pay for your stay at this facility unless you require daily skilled care.

 

Example 2: Beneficiary no longer requires daily skilled care but wants to continue residing in the SNF.

Care: Inpatient Skilled Nursing Facility Stay

Reason Medicare May Not Pay: You don’t require skilled care on a daily basis. Medicare won’t pay for your stay at this facility unless you need daily skilled care for your medical condition.

 

Example 3: Beneficiary no longer requires skilled therapy services and wants to continue residing in the SNF.

Care: Inpatient Skilled Nursing Facility Stay

Reason Medicare May Not Pay: You need help with repetitive exercises and walking, and you don’t require skilled care. Medicare won’t pay for your stay at this facility unless you need daily skilled care.

 

Follow the rules for resident rep signatures

 

“In cases when the resident representative is going to sign, you need to review their signature,” advises Baker. “CMS has included a fix with the new SNF ABN process to help ensure that the resident representative is actually who signed the notice. So if the resident representative signs, you’re required to make sure that you add in that they’re the representative in parentheses. In addition, if the resident representative’s signature is illegible, their name has to be printed as well.”

 

The following excerpt from Section 5 (Signature and Date) of the revised instructions explains in detail:

 

The beneficiary or their authorized representative must sign the signature box to acknowledge that they read and understood the notice. The SNF may fill in the date if the beneficiary needs help. This date should reflect the date that the SNF gave the notice to the beneficiary in-person, or when appropriate, the date contact was made with the beneficiary’s authorized representative by phone. If an authorized representative signs for the beneficiary, write “(rep)” or “(representative)” next to the signature. If the authorized representative’s signature is not clearly legible, the authorized representative’s name must be printed. If the beneficiary refuses to choose an option and/or refuses to sign the SNF ABN when required, the SNF should annotate the original copy of the SNF ABN indicating the refusal to sign and may list a witness to the refusal. The SNF should consider not furnishing the care.

 

Pay attention to the rules re: secondary insurance

 

“The instructions for the revised SNF ABN clarify that the resident should choose Option 1 on the SNF ABN form if the SNF needs to bill Medicare Part A to obtain a denial in order to bill the resident’s insurance company,” says Hedrick.

Comments:
Add New Comment
Name*:  
Email*:  
Website:
Title*:  
Comment*: