Timing of notice not clear in model letter
Part of the confusion involving the number of grace days allowed under the Medicare Hospital Initiated Notice of Non-Coverage (HINN) stems from an error in the model HINN letter published in the Health Care Financing Administration (HCFA) Hospital Manual, says consultant Elgin K. Kennedy, MD, of San Mateo, CA. A footnote in the model letter specifies that hospitals insert a date that is the third day following the date of receipt of the hospital notice, when in fact, the date of the second day should be inserted, contends Kennedy, who is lobbying to get the error corrected. In other words, if a patient is given notice on July 1 (any time before midnight), the hospital can begin billing at 12:01 a.m. on July 4. That means that the patient has two grace days, July 2 and July 3, before being billed.
Kennedy suggests contacting the state Peer Review Organization (PRO) if utilization management professionals are confused about how the HINN should read. If the PRO disagrees, Kennedy suggests citing the HCFA regulation that reads, "Customary charges will be made for continued hospital care beyond the second day following the date of the notice."
Doris Barham, health insurance specialist of the HCFA in Baltimore, admits that the wording of the model letter can cause confusion, but she disagrees that it contains an error. In any case, she says HCFA is reviewing the letter and may alter it to include times of day in the notice to clarify matters. *
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