NAHAM Launches Monitoring Program for Key Patient Access Regulatory Issues

NAHAM’s Policy Development and Government Relations (PD & GR) Committee has identified and will actively monitor nine regulatory issues that impact the daily workflow of Patient Access.  Most are regulatory items required specifically by the Centers for Medicare and Medicaid Services (CMS):

•         the Important Message from Medicare (IM)
•          the Medical Outpatient Observation Notice (MOON)
•          the Advance Beneficiary Notice of Noncoverage (ABN)
•          the Emergency Medical Treatment & Labor Act (EMTALA) requirements
•         Medicare Secondary Payer (MSP)
•          CMS documentation requirements for Administrative Gender.  T

The Committee is also monitoring

•          501(r) Pricing Transparency
•          HIPAA privacy rules

Visit the NAHAM Key Issues Management Page on the NAHAM website. Membership is not required to view the page.  Each issue is briefly explained and source material is provided through outside sources and NAHAM toolkits. The NAHAM toolkits include best practices and guidance documents relating to CMS surveys, Joint Commission surveys, and positive patient identification.  NAHAM Toolkits are available on the NAHAM website as a members-only benefit.

To highlight the Medical Outpatient Observation Notice (MOON), the Key Issues Management Page includes a brief description that Hospitals and CAHs are required to provide the MOON to Medicare beneficiaries (including Medicare Advantage health plan enrollees) informing them that they are outpatients receiving observation services and are not inpatients of the hospital.  The description also includes background information that the MOON is mandated by the Federal Notice of Observation Treatment and Implication for Care Eligibility Act (NOTICE Act), passed on August 6, 2015. This law amended Section 1866(a)(1) of the Social Security Act by adding new subparagraph (Y) that requires hospitals and CAHs to provide written notification and an oral explanation of such notification to individuals receiving observation services as outpatients for more than 24 hours.

Resources posted on the webpage include a link to Form CMS-10611, a link to CMS’s Frequently Asked Questions for the MOON, and instructions for the use and completion of the MOON.  There is a link to section 400 of Chapter 30 of the CMS Claims Processing Manual where full instructions on the MOON’s use, execution, and delivery are included.  There is also a link to the basic CMS landing page for the MOON and a link to NAHAM’s CMS Survey Toolkit which includes an entry for “Regulations and Guidance: Medical Outpatient Observation Notice (MOON).

In addition to this resource, the PD&GR Committee will respond to questions and host discussions on NAHAM’s Access Forum for regulatory issues.  Members are encouraged to subscribe to the Regulatory Issue forum and post their questions about these and other regulatory issues here. The Regulatory Issues Forum is open to both members and non-members.  

New Medicare Cards Are On Their Way; Mailings for 20 States, the District of Columbia, and 3 Territories Already Complete

CMS is well underway with its program of mailing out the new Medicare Cards.  You can find the updated mailing strategy here (https://www.cms.gov/Medicare/New-Medicare-Card/NMC-Mailing-Strategy.pdf). 

The mailing strategy is based on waves of mailing in clusters of states, with waves 1, 2 and 3 completed. It’s important to note that these waves of new card mailing are for currently eligible beneficiaries, those already in possession of the old card version.  Newly eligible beneficiaries began receiving their new cards as of April of this year.  

The first three waves targeted existing beneficiaries in the following states, the District of Columbia, and territories (listed in alphabetical order, not in order of the first three waves): Alaska, American Samoa, Arkansas, California, Delaware, District of Columbia, Guam, Hawaii, Illinois, Indiana, Iowa, Kansas, Maryland, Minnesota, Nebraska, North Dakota, Northern Mariana Islands, Oklahoma, Oregon, Pennsylvania, South Dakota, Virginia, West Virginia, and Wisconsin.

Patients from these states who have not received their new card should go to their MyMedicare.gov account (or to create an account if they don’t already have one), or call 1-800-MEDICARE (1-800-633-4227).

As a healthcare provider, there is a way to check on the status of a patient’s card AND find their new MBI. Find out how here (https://www.cms.gov/Medicare/New-Medicare-Card/Providers/Getting-MBIs.html). 

You can also share CMS’s “Still Waiting for Your New Card?” found here (https://www.cms.gov/Medicare/New-Medicare-Card/Outreach-and-Education/Tear-Off-for-After-Card-Mailing-Ends.pdf).

Wave 4, targeting Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, and Vermont, started in July.  Wave 5, targeting Alabama, Florida, Georgia, North Carolina, and South Carolina, started in August.  

Waves 6 and 7 are scheduled for sometime after August for the states of Arizona, Colorado, Idaho, Montana, Nevada, New Mexico, Utah, Washington, and Wyoming (Wave 6) and Kentucky, Louisiana, Mississippi, Missouri, Ohio, Puerto Rico, Tennessee, and Virgin Islands (Wave 7).

There is also an online map that tracks the mailing waves found here (https://www.medicare.gov/NewCard/).

Remind your patients that just because their neighbor or others known to them have received their new cards, the fact that they haven’t yet is no reason for alarm.  Again, if your patient lives in one of the states in Waves 1, 2 or 3 and haven’t received their new card, they should contact Medicare.  If they live in a Wave 4 or 5 state and haven’t yet received their new card, be patient.

Several things to remember (and to remind your patients):

1. The patient’s new card will automatically come to the patient.  The patient doesn’t need to do anything as long as their address is updated with the Social Security Administration. Patients can confirm that by visiting their account (or creating one) at My Social Security Account at https://www.ssa.gov/myaccount/. 

2. Once the beneficiary gets their new Medicare card, they should destroy their old Medicare card, and they should start using their new card right away.

3.  Look out for scams.  Medicare will never call the beneficiary and ask them to give personal or private information as a prerequisite to receiving their new Medicare number and card.  If someone asks for their information, for money, or threatens to cancel health benefits if they don’t share their personal information, hang up and call Medicare at 1-800-MEDICARE (1-800-633-4227).

As a reminder, the new cards will no longer have the beneficiary’s Social Security Number or the beneficiary’s gender. The new Medicare numbers are a randomly generated, unique combination of numbers and letters.  There is no significance in the order or these numbers and letters. You should begin using the new MBIs as soon as possible. CMS will officially transition to MBI numbers only in January, 2020.