Inpatient Hospital Issued Notices

Applies to: All hospitals

Medicare beneficiaries and hospitals have certain rights and protections related to financial liability and appeals under the Medicare Program. These financial liability and appeal rights and protections are communicated to Medicare beneficiaries through notices hospitals give to them. We have outlined these notices below.

Important Message from Medicare

Hospital staff must issue the initial IM and follow-up IM to all beneficiaries, or their representative, during an inpatient hospital stay to inform them of their discharge appeal rights.

Initial Important Message from Medicare: Form CMS-10065 (formerly CMS-R-193)

Hospital staff must deliver the IM to all inpatients, including those in the hospital for a short stay.

Timing of Initial IM Delivery

Pre-admission: Up to seven days before admission
At admission: At admission
After admission: Up to two days following admission

Follow-Up Copy of the IM – Second IM (Form CMS-10065)

Hospital staff must deliver the follow-up copy of the IM within two days of discharge.

If delivery of the first IM is within two calendar days of the date of discharge, then no follow-up notice is required.
Timing of follow-up (Second) IM

No sooner than two days before discharge
No later than four hours prior to discharge

Hospital Issued Notices of Noncoverage

Hospital staff issues one of four different HINNs to notify a beneficiary, or their representative, during an inpatient stay of potential financial liability. This also applies to direct admissions to swing beds.

HINN 1 – Preadmission/Admission HINN

The hospital’s utilization review committee may issue a preadmission/admission HINN.
QIOs may also issue a pre-admission/admission HINN after having been contacted by a hospital regarding care the hospital believed to be medically unnecessary, inappropriate, or custodial.

The hospital is not required to obtain the attending physician's concurrence, or the QIO's, prior to issuing the admission/admission HINN (HINN 1).

Timing: Issue completed HINN 1 prior to inpatient admission for an entirely noncovered stay
- Preadmission: Beneficiary liable for all services during provided during inpatient stay
- Admission:
  - Issued at/before 3:00 p.m. on the day of admission: Beneficiary is liable for customary charges for all services furnished after receipt of the HINN 1.
    - Except for those services for which the beneficiary is eligible to receive payment under Part B.
  - Issued after 3:00 p.m. on the day of admission: Beneficiary is liable for customary charges for all services furnished on the day following the day of receipt of the HINN 1.
    - Except for those services for which the beneficiary is eligible to receive payment under Part B.

HINN 10 – Notice of Hospital Requested Review (HRR)

The hospital may issue a HINN 10 when the hospital determines the beneficiary no longer requires inpatient care and is requesting BFCC-QIO review of the discharge decision. However, hospital staff were unable to obtain a physician’s agreement.

Timing: Issue a completed HINN 10 to notify the beneficiary that you requested the review.

HINN 11

The hospital may issue a HINN 11 when planning to charge the beneficiary for certain noncovered items and services during a covered inpatient stay when certain conditions apply.

Conditions: Noncovered items and services at issue must be a diagnostic or therapeutic service excluded from coverage as medically unnecessary. In addition, the beneficiary must require continued hospital inpatient care.

Issued when you are providing noncovered items or services during an otherwise covered inpatient stay and are planning to charge the beneficiary for the noncovered services.

Note: The hospital may continue to opt NOT to charge the beneficiary for noncovered services. Issue a HINN 11 when you are planning to charge the beneficiary.

Timing: Issue a completed HINN 11 either prior to admission or at admission, or at any point during an inpatient stay. The HINN 11 is immediately effective if understood and signed by the beneficiary.

HINN 12

The hospital may issue a HINN 12 to inform a beneficiary of potential financial liability for a noncovered continued inpatient hospital stay and the DND explains the specific reasons for the discharge.

The HINN 12 and DND (CMS-10066) is issued only if a beneficiary requests an appeal of the discharge decision.

Process:

Issue a follow-up copy of the IM (CMS-10065) to every beneficiary within two days of a planned discharge from an inpatient stay.
Issue a HINN 12 in situations where the beneficiary disagrees with the inpatient discharge date and the hospital plans to charge the beneficiary for the noncovered portion of their inpatient stay.
- Also issue a DND with the HINN 12.
Note: The hospital may opt NOT to charge the beneficiary for noncovered services. Issue the HINN 12 only when you are planning to charge the beneficiary. The HINN 12 informs the beneficiary of their potential financial liability for a noncovered continued stay.
Timing: Deliver a completed HINN 12 and DND upon QIO notification that the beneficiary has requested an appeal of the discharge from an inpatient hospital stay.
- No later than noon of the day after QIO notification of the appeal request

Detailed Notice of Discharge (DND) – CMS-10066

The hospital may issue a DND during an inpatient hospital stay, when the beneficiary, or representative, disagrees with inpatient discharge:

A beneficiary who receives a follow-up IM and disagrees with the discharge may request an expedited determination by the appropriate BFCC-QIO for the state where the services were provided. The beneficiary must contact the BFCC-QIO by midnight of the day of discharge, before leaving the hospital. The beneficiary may contact the BFCC-QIO by telephone or in writing.
- Timing: The beneficiary/representative must contact the BFCC-QIO by midnight of the day of discharge, before leaving the hospital.
The hospital should issue a DND to a beneficiary, or representative, as soon as possible after an expedited determination by the BFCC-QIO is requested.
- Timing: No later than noon of the day after the BFCC-QIO notification to the hospital
Issue a HINN 12 in addition to the Hospital Discharge Appeal Notice to inform beneficiaries of their potential financial liability for a noncovered continued inpatient stay.