HINNs Inform Patients When Services Are Not Covered by Insurance
The difficulty with the Hospital-Issued Notice of Noncoverage (HINN) is deciding which HINN to use and when to deliver it, says Jackie Birmingham, RN, BSN, MS, clinical leadership for naviHealth, a Cardinal Health Company based in Newton, MA, that specializes in transition management.
For example, hospitals may choose to deliver HINNs to beneficiaries prior to admission, at admission, or at any point in the stay when the hospital determines that the care the patient is receiving or is about to receive is not covered because it’s not medically necessary, is not delivered in the most appropriate setting, or is custodial in nature, she points out.
“HINN” is the frequently used term for Beneficiary Notice Initiatives, or BNIs, Birmingham adds. “Medicare states that ‘both Medicare beneficiaries and providers have certain rights and protections related to financial liability under the Fee-for-Service Medicare and Medicare Advantage programs. These financial liability and appeal rights and protections are communicated to beneficiaries through notices given by providers.’” She points out that there also are BNIs for patients receiving care from home health agencies and skilled nursing facilities.
Hospitals are not required to give patients a HINN when their care will not be covered, but patients can’t be charged unless they are given a HINN, Birmingham adds.
“Failure to deliver a HINN and document it can have a real snowball effect down the road when hospitals are audited,” she says. If a patient does not meet medical necessity but continues to stay in the hospital, or they receive services that could be provided at a lower level of care, the hospital has to prove it made an effort to discharge the patient or that the patient was notified that services weren’t covered. Otherwise, the hospital is at risk of having the entire claim denied and the denial upheld, she adds.
CMS expects hospitals to have a process to deliver a HINN, says Beverly Cunningham, RN, MS, consultant and partner at Oklahoma-based Case Management Concepts. (For a list of the HINNs and when each should be given, see story in this issue.)
For instance, if a patient is medically stable and can be treated at a lower level of care but does not want to leave or doesn’t feel comfortable with the discharge plan, he or she should receive HINN 12, notifying him or her of potential financial liability, Cunningham says.
Before that situation arises, case managers should take steps to avoid any surprises in the discharge process and minimize the possibility patients will appeal their discharges, Cunningham advises. The ideal situation is for the physician and the case manager or social worker to have ongoing discussions about the discharge process with the patient and family members to ensure the patient and family understand the expected discharge date.
“A lot of times, patients’ reluctance to be discharged can be managed by good communication between the patient and family, the case management staff, and the physician,” Cunningham says.
When patients wish to appeal, case management leadership should ensure the patient understands the process and knows that if the Quality Improvement Organization (QIO) agrees that the patient should be discharged, the patient will be responsible for the bill if he or she stays, she says.
“The HINN 12 doesn’t mean they can’t stay. It tells patients that they are putting themselves in a position so they could receive a bill from the provider,” says Mindy Owen, RN, CRRN, CCM, principal owner of Phoenix Healthcare Associates in Coral Springs, FL, and senior consultant for the Center for Case Management.
Sometimes case managers can use the HINN as a tool that assists in difficult conversation with patients and family members about a discharge to the next level of care, Owen says.
The HINN can be useful in cases where the patient or family members have not had a conversation about what the next level of care will look like, Owen says. Possible questions include whether a family member is going to stay in the patient’s home for a short time to provide care, or if the patient is going to a family member’s home in the short term. Or, is the next step a stay in a skilled nursing facility, a subacute unit, or inpatient rehabilitation facility?
“When the patient and family talk about the options and their financial responsibility once the need for inpatient care in an acute care hospital is complete, everybody may be ready to come to the table and talk about the next level of care,” Owen says.
When a physician orders a test or procedure that is unrelated to the reason for admission, the first thing the case manager should do is talk to the physician to explain the CMS medical necessity rules, Cunningham says.
Make sure the physician has a clear understanding of Medicare rules and knows that the hospital will be denied payment and the patient will be financially responsible for the costs, Owen adds.
If the doctor persists or the patient insists on having the procedure, it’s time to deliver the HINN 11 to the patient, Owen says.
If the family requested the uncovered service and continues to request it, inform them of the cost, Cunningham says.
“Hospitals can’t just do the test or procedure and bill patients for it. The HINN has to be issued to inform them of their financial responsibility,” she says.
The difficulty with the Hospital-Issued Notices of Noncoverage is deciding which to use and when to deliver it.
Subscribe Now for Access
You have reached your article limit for the month. We hope you found our articles both enjoyable and insightful. For information on new subscriptions, product trials, alternative billing arrangements or group and site discounts please call 800-688-2421. We look forward to having you as a long-term member of the Relias Media community.