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Invalid ABNs and HHCCNs

A home health agency can be held liable for charges they believed Medicare would not cover if the Advance Beneficiary Notice (ABN) or the Home Health Change of Care Notice (HHCCN) given to the beneficiary is determined to be invalid. For instructions on completing the ABN, refer to the FFS ABNExternal Website Web page on the Centers for Medicare & Medicaid Services (CMS) website.

The following are scenarios of when an ABN or HHCCN would be considered invalid:

  • Noncompliance with the CMS-R-131 (ABN) or CMS-10280 (HHCCN) format requirements. (Altering the font, reformatting the form, etc., is not allowed.)
  • Pre-selection of an option. Exception: For dual eligible beneficiaries, home health agencies are permitted to direct the beneficiary to select a particular option box to facilitate coverage by another payer.
  • Not using at least one reason why Medicare may not pay for each item/services listed.
  • Using undefined abbreviations to explain services provided and/or reasons for denial of service. For example, using SNV as an abbreviation for skilled nursing visits, or using HB as an abbreviation for homebound is not acceptable. An abbreviation such as "PT" that has multiple meanings should be spelled out at least once next to the abbreviation of the word.
  • Not providing clear, specific reason(s) for why the home health services will not be covered by Medicare. For example, "not a covered benefit under Medicare" or "does not meet Medicare guidelines".
  • Not listing a cost estimate or the costs listed are unclear. For example, the home health agency will be providing multiple services but only lists one cost per visit or the HHA lists a dollar amount, but there are no services or timeframe listed to explain the cost. The cost needs to be specific to each discipline billed and for a specific time period.
  • An ABN that was not signed and/or dated by the beneficiary/representative is not acceptable.

Updated: 04.24.17

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