An important update providers should implement immediately is the revised fee-for-service ABN, or Advanced Beneficiary Notice of Non-Coverage form. This form is used when a patient requests, or is expected to require, services that are not covered by Medicare, making it a critical component of both patient communication and proper billing practices.
The ABN is used in both home health and hospice settings. The form number is CMS R131. While it is already in effect, the final deadline for implementation of the updated version is May 12, 2026. Be sure to implement it promptly and confirm that all Start of Care packets include the correct, updated form.
Also, keep in mind the other required forms that may not be used as often, including the Notice of Medicare Non-Coverage and the Detailed Explanation of Non-Covered Services. The Notice of Medicare Non-Coverage must be issued within two days prior to discharge and was updated in 2025. While there are no new updates at this time, there has been recent discussion among agencies, particularly around Medicare Advantage plans, emphasizing that the fee-for-service Medicare Notice of Non-Coverage must be provided to any patient being discharged within that two-day window, including the BFCC-QIO information on the form.
Prior to 2025, agencies could include Medicare Advantage plan contact information when discharging a Medicare Advantage patient. That is no longer permitted. The Notice of Medicare Non-Coverage must now be issued to both traditional fee-for-service Medicare and Medicare Advantage beneficiaries using the same requirements. This includes providing the BFCC-QIO information for Medicare Advantage patients, just as you would for traditional Medicare patients. Medicare Advantage plan contact information can no longer be used for discharge appeals.
If you need help determining whether you’re using the correct forms or have questions about compliance strategies, please reach out to us.
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