CMS-R-131 Comment #2

BECK'SHOMEHEALTH
CAREPRODUCTS,
INC.
AND INDUSTRIAL
GASES,INC.
BECK'SMEDICAL
1411 Locust Street
Eldorado, Illinois 62930
Phone 618-273-9019
FAX 618-273-4832

March 5,2007
CMS, Office of Strategic Operations and Regulatory Affairs
Division of Regulations Development - C
Attention: Bonnie L. Harkless
Room C4-26-05
7500 Security Blvd.
Baltimore, Maryland 2 1244- 1850
RE: Revised Advanced Beneficiary Notice
Dear Ms. Harkless:
In response to the offer to submit comments regarding the revised ABN, we would. like to take this
opportunity to share our observations. Our overall opinion is that this form will be overly confusing
for Medicare beneficiaries. However, we do feel that the opening explanation to the beneficiary is well
stated, as compared to the current language. Some of the observations we made are detailed as
,
follows.
First, Section E does not allow sufficient area for detailing the reason why Medicare will likely not .
cover a particular item. The current general ABN has a significantly larger area for explaining this
information to the beneficiary. This is particularly important for DME suppliers, since the coverage of
equipment and supplies is based on lengthy and specific guidelines as set forth in the LCD's.
Second, we feel that the bulleted items below the itemlservice will be confusing to beneficiaries. The
current version is stated in a way that is clear and concise. This version has too much bold text. We
do, however, like the addition of the Medicare contact information.
Lastly, in Box G, there appears to only be a check box for Option 1. Also, Option 3 states that the
beneficiary will be refunded if Medicare pays. It does not specify where the refund payment will come
from. We do not refund a patient who signs an ABN, since the item(s) would be billed non-assigned.
In this case, Medicare will make payment to the beneficiary, if the item is deemed to be covered. The
revised ABN may be interpreted by the beneficiary to mean that we, the provider, will refund the
payment made by the beneficiary, which is not the case.
Thank you for the opportunity to respond. We hope that our comments and suggestions will be helpful
in determining the final ABN.
Sincerely,

~ a rRandel
i
Billing Specialist