CMS-R-131 Comment #12 thru #14

Williams Bros.
HEALTH CARE PHARMACY
R,cellence since 1899
April 2,2007
CMS
Office of Strategic Operations and RegulatoryAffairs
Division of Regulations Development- C
Attention: Bonnie L. Harkless
Room C4-26-05
7500 Security Blvd.
Battimore, Maryland 21244-1850

Dear Ms Harkless
Regarding the proposed revision of Advance Beneficiary Notice of Noncoverage (ABN), Document
CMS-R-131:
We have reviewed the proposed revisions to the ABN and appreciate the changes made. The overall
layout is much improved. Specifically, the Estimated Cost is now easier to see and being placed with
the Item and Reason should enhance beneficiary understandingof this process. Including the option of
allowing the beneficiary to pay out of pocket is also a significant improvement.
Sincerely.

n

/

HME Binmg

Corporate Office: 10 Williams Bros. Drive Washington, Indiana 47501
(812) 254-2497 1-800-264-0064www.wbhcp.com

April 2, 2007

CMS, Office of Strategic Operations and Regulatory Affairs,
Division of Regulations Development - C
Att: Bonnie L. Harkless
ROOHIC4-26-05
7500 Security Blvd.
Baltimore, Maryland 2 1244- 1850
Dear Bonnie:
Tn accordance with the CMS requests for Public Comment on the Revised Advance
Beneficiary Notice (ABN) please review the following comments:
1. Regarding payment for services of oxygen equipment there is stated in the new
payment rules that 1 unit equals 15 minutes and 30 minutes is the maximum for a
service call. We cover a wide area of a 60 mile radius. This fee doesn't cover
fuel or drive time to get to a patient home and back. This only covers if a
maintenance performance is done on the equipment itself. Will there be a
payment for travel to get to the home or does the patient need to bring their
equipment into the store?
2. Since Medicare will no longer cover 6 month repair and maintenance on capped
rental DME are we allowed to contact the patient to remind them of service due
on their equipment? If we don't call on a regular basis will we be held
accountable for not tracking the service and repair maintenance or will the "new
owner?" Will there be a catch so that money must be paid back if certain service
and maintenance follow-up of some sort is not done?
3. In light of the above will there be a place on the ABN that will allow the supplier
to explain these concerns to the patients understanding?
Thank you for considering my comments.

Susanne Kanen
President
Medicare # 0736200001

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
Dear Ms. Harkless:
In response to the opportunity to comment on the proposed revision of the Advanced Beneficiary
Form (CMS-R-13 l), we have the following questions and remarks.

-

Can the references in the opening paragraph to "health care provider" be changed to "health
care providers"?
o With the ability of two separate providers to place their names on the form header
and represent the professional and technical portions of the service, it may help a
beneficiary in recognizing that the ABN is being used jointly.
In the third bullet point with the mention of billing insurance if options 2 or 3 are chosen,
beneficiaries may transfer the intent of this form to the other insurance listed in (H). Can a
disclaimer be added in the third bullet point that this form does not apply to any insurance
represented in (H)?
o This will help reinforce that this form only applies to Medicare and eliminate
potential confusion between beneficiaries, providers, and third party insurances.
o Language such as "other insurance is not required to comply with this form" is
would augment the statement "though Medicare cannot require us to do
[insurance billing]"
Can a statement be included on the notice about the duration of its effectiveness?
o For some beneficiaries with repeat services, it important to define whether this
applies one time for a particular date of service or if another trigger for expiration
would apply. Tnis is imporrant where a beneficiay would desire to revoke the
ABN for future services.
Thank you for your consideration of these thoughts. Should you have further need to contact
me, I may be reached at (608) 826-245 1.

- Carrie ~ i k k n
Compliance Manager
SVA Healthcare Services, LLC

1221 John Q . Hammons Drive P.O.Box 44966, Madison, W I 53744-4966 608-831-8181 Fax: 608-831-4243 www.sva.com