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MIR-2006-8AB, August 2006
MLN Matters. . .Information for Medicare Providers
(Issued by the Centers for Medicare & Medicaid Services)
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New Use of Hospital Issued Notice of Noncoverage (HINN)
Provider Types Affected
Providers submitting claims to Medicare Fiscal Intermediaries (FIs) for hospital inpatient services
Provider Action Needed
Impact to You
This article is based on Change Request (CR) 5070, which introduces model language for a new Hospital Issued Notice of Noncoverage (HINN), specifically HINN 11, and describes its uses with hospital inpatients.
What You Need to Know
CR5070 offers model language for a new HINN that may be used as a liability notice for fee-for-service inpatient hospital beneficiaries who are due to receive specific diagnostic or therapeutic procedures that are separate from treatment covered/paid/bundled into the inpatient stay.
What You Need to Do
See the Background and Additional Information sections of this article for further details regarding these changes.
Background
Limitation of Liability (LOL) notices are required under Section 1879 of the Social Security Act ( http://www.ssa.gov/OP_Home/ssact/title18/1879.htm  ) in order to hold beneficiaries liable for certain noncovered services. The Hospital Issued Notice of Noncoverage (HINN) is the only limitation of liability (LOL) notice for fee-for-service beneficiaries who are hospital inpatients, but traditionally these notices have only addressed entire hospital stays.
While there are several different versions of the HINN, none of the current versions adequately address the ability of hospitals to charge their inpatients for certain noncovered services that are severable from the inpatient stay (i.e., not bundled or integral to payment or treatment for the diagnoses/reasons justifying the stay under Medicare policy).
The ability to charge beneficiaries for such items (medically unnecessary diagnostic and therapeutic services) is codified under the Code of Federal Regulations at 42 CFR 412.42 (d); ( http://www.gpoaccess.gov/cfr/retrieve.html ).
The attachment to CR5070 provides model language for a new HINN to fit this specific case, “HINN 11,” and instructions for use of this language are also provided. This attachment to CR5070 includes the following major sections:
- Introduction (HINN 11 Model Language and Instructions)
- Use of HINN 11
- Delivery of HINN 11
- Model Language
- Completion of the HINN 11
- Procedures After Signature
Quality Improvement Organizations (QIOs), which review most other HINNs, will not automatically review this HINN.
In this case, QIOs will only exercise medical judgment and review cases related to this new HINN (after services have been delivered) when specifically requested by the:
- Involved beneficiary;
- Beneficiary representative; or
- Intermediary.
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Intermediaries have the discretion to review this HINN for other than inpatient hospital stays if relevant to a claim being reviewed as part of the progressive corrective action process. Intermediaries must include this cost as part of the review of the claim.
Implementation
The implementation date for the instruction is September 18, 2006.
Additional Information
For complete details, including the revised manual section and model language, please see the official instruction (CR5070) issued to your intermediary regarding this change. That instruction may be viewed at http://www.cms.hhs.gov/Transmittals/downloads/R982CP.pdf  on the CMS Web site.
Hospitals may choose to begin using this HINN immediately and need not wait for the September 18, 2006 implementation date.
If you have any questions, please contact your intermediary at their toll-free number, which may be found at http://www.cms.hhs.gov/MLNProducts/downloads/CallCenterTollNumDirectory.pdf on the CMS Web site.
Disclaimer
This article was prepared as a service to the public and is not intended to grant rights or impose obligations. This article may contain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be a general summary. It is not intended to take the place of either the written law or regulations. We encourage readers to review the specific statutes, regulations and other interpretive materials for a full and accurate statement of their contents.
MLN Matters Number: MM5070
Pub. 100-4, Transmittal# R982CP, CR# 5070
Related CR Release Date: June 16, 2006
Effective Date: September 18, 2006
Implementation Date: September 18, 2006
Do you have your NPI? National Provider Identifiers (NPIs) will be required on claims sent on or after May 23, 2007. Every health care provider needs to get an NPI. Learn more about the NPI and how to apply for an NPI by visiting http://www.cms.hhs.gov/NationalProvIdentStand/ on the CMS Web site.
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