CMS-R-131 Comment # 1

- MAAMA-

Multi-disciplinary Academy of Affiliated Medical Arts,
2491 Sirius Star Street Henderson, Nevada 89044
On The Web At: http://www.maama.org

A

I

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 21244-1850
May 27,2007
Re: ABN (CMS-R-131)
Dear Ms. Harkless:
We are writing in comment to the proposed changes to the ABN (CMS-R-131).
Frequently, services covered under an advance notice are repetitive throughout a course of treatment
and would logically be subject to denial in every instance. Examples include the repeated use of certain
modalities and/or methods of treatment that are necessary for patient's rrecovery but are routinely
excluded from Medicare coverage for various reasons.
Since the original notice details the procedures or services and the regulations for use of the form require
discussion and explanation, we feel that one notice and patient election regarding those services should
suffice for the entire course of treatment.
We respedwely suggest that the ABN be formatted to include additional sections to reflect if the notice '
applies to a single incident or to a "series of incidents" that may occur during a stated treatment period.
An example would be adding an additional entry where language could cover the anticipated inclusive
dates of the services subject to noncoverage. (ie: 'Please note that the services listed would require
your personal payment for each instance during your entire treatment regimen which is anticipated to
require
visits during the next
weeks")
Naturally, to protect the beneficiary and the system, provisions should be adopted to limit the inclusive
periods covered by the notice to a single plan with a reasonable time frame and require an additional
notice for revisions to the original plan of care.
We appreciate your consideration.

Best regards,

R.L. Ramsdell, PhD, FACFEI, DABFE, CFC, LFMAAMA.
Executive Director

Voice (702)838-0054

Fax (702)260-6577

e-mail: [email protected]