CMS issues guidance for flexible delivery of beneficiary notices

As hospitals deal with concerns related to the spread of COVID-19, CMS issued guidance on March 26 regarding the delivery of the Important Message from Medicare (IM), Detailed Noticed of Discharge (DND), Medicare Outpatient Observation Notice (MOON), and several other notices.

In order to avoid unnecessary contact with patients, case managers and other healthcare professionals who have treated patients with suspected or confirmed cases of COVID-19 are encouraged by CMS to take advantage of flexible delivery options of the IM, DND, MOON, and other notices.

According to CMS, hard copies of notices may be delivered to a beneficiary by any hospital worker able to enter a room safely. When notices are delivered in this manner, a contact phone number should be provided in case the beneficiary has any questions that cannot be answered by the employee who drops off the form.

Organizations are not required to deliver hard copies of notices, however. If a hard copy cannot be dropped off, notices may be delivered via email so long as the beneficiary has access to email in the isolation room, according to CMS. The notices should be annotated with the circumstances of the delivery, including the person delivering the notice, and when and to where the email was sent.

In lieu of direct or email delivery to the beneficiary, notices can be delivered to offsite beneficiary representatives via telephone or secure email. As is the case in email delivery to a beneficiary, the notices should include information about the timing and recipient of the email or phone call.

When delivering notices via email, hospitals must meet HIPAA privacy and security standards, according to CMS.

Though CMS is granting flexibility in the way notices can be delivered, the timeframe for delivery for each of the notices is unchanged.

CMS encourages healthcare providers to review specifics of notice delivery, as set forth in Chapter 30 of the Medicare Claims Processing Manual.

Beginning April 1, hospitals must use the revised versions of the IM, DND, and MOON forms. The new versions of the IM and DND forms include substantive changes. For example, in the DND form, hospitals must provide a detailed explanation of why the patient’s hospital stay is no longer covered, and the specific Medicare coverage rules and policies used to make this decision. More information on the new forms can be found in the March issue of Case Management Monthly.

CMS has not indicated any change to the April 1 deadline to implement the new versions of these forms.