SECTION G BILLING AND CLAIMS



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CLAIMS PAYMENT METHODS SECTION G Harbor Advantage (HMO) offers 2 forms of payment for services provided; paper check and electronic funds transfer (direct deposit). Electronic Funds Transfer (EFT) Harbor Advantage encourages practices to use EFT. EFT allows payments to be deposited electronically directly into a designated bank account. Some of the benefits of EFT are: Receipt of payment directly into your account within an average of 3-5 business days once payment is released. No need to manually deposit your checks. Capability to view remits on-line through our secure website. (Coming Soon! You must be registered for access with a secured login.) Allows for no delay between receipt of dollars and the ability to post payment. Please visit our website at: https://www.harborhealthadvantage.com/providers/forms in order to download and complete the EFT/ERA form or contact Network Management for a form to be faxed to your practice. CLAIMS STATUS Coming Soon: Providers that are registered through the Harbor Advantage website, for secured access to log in, can check status of their submitted claims. Once claims have been data entered, claims will reflect as showing pending, paid or denied. To register for secured access to the Provider Portal, go directly to our website or contact Network Management for a form to be faxed to your practice. Ø Provider Portal URL to be posted soon! CLAIM SUBMISSION INFORMATION We encourage you to consider EDI for your practice. Submitting claims electronically can save your practice time and money, allows for faster processing and payment, and documents timely claim submission For questions or assistance with this process, please contact our EDI Specialist at (602) 824-3861. Our vendor: Emdeon www.emdeon.com (866) 506-2830 or (800) 296-3736 Payer ID: 58305 Page G - 1

If you must mail your claim: Harbor Advantage (HMO) Claims Department P.O. Box 37200 Phoenix, AZ 85069 Timely Filing For all covered services provided to Harbor Advantage members, Harbor Advantage must receive a completed claim form within 180 days from the date of service from contracted providers. Noncontracted providers have a grace period of one (1) calendar year from the date of service to file a completed claim. Practice/Facility Name and Address Please notify Harbor Advantage of all addresses and billing vendor changes. Each provider must report all services to Harbor Advantage either by encounter submissions and/or the appropriate claim form for payment. Harbor Advantage registers each provider under the provider name and the legal business name as registered with the IRS. In order to receive reimbursement, your claim submission must match the legal name of the business and the payment address on file. All changes to your payment name and address must be submitted in writing to Network Management. As a reminder, Harbor Advantage does not accept business names unless you are registered with the IRS to use that name. Example: Dr Smith is listed with the IRS as John Smith, MD, PC. The name on his door is Smith Family Practice. Smith Family Practice is not registered with the IRS. Claims should be submitted under the name John Smith, MD, PC in box 33. Harbor Advantage utilizes optical character recognition (OCR) when processing claims. It is extremely important that the name matches our records in order for the system to correctly identify the pay-to information. Failure to have the correct name on your claim may delay payment. Tax Identification Number Each provider must report the Tax I.D. number under which they wish to be paid. It is imperative that Harbor Advantage be notified of any Tax I.D. number or name changes. Failure to provide Harbor Advantage with Tax I.D. or name changes may result in denial of claims or backup withholding per Internal Revenue Service guidelines. NPI Providers are required to use the appropriate NPI on every claim submitted. Harbor Advantage will deny paper claims and reject electronic claims submitted without the appropriate NPI numbers. Providers that bill with a facility/legal entity name (in box 33), are required to obtain a Type II (Organizational) NPI number for the legal entity. Page G - 2

CMS 1500 Submissions For providers who submit for reimbursement on a CMS 1500 form, the facility s NPI number must appear in box 33A along with the provider s facility name as registered with the IRS in box 33 along with the rendering provider s NPI in box 24J. If you do not have a facility NPI, the rendering provider s NPI number must appear in box 33A. UB-04 Submissions For providers/facilities who submit for reimbursement on a UB-04 form, the facility s NPI number must appear in box 56. For those that enter the attending, operating and/or other physicians, the NPI number must be placed in boxes 76-79. Rendering Provider The rendering provider is the individual who provided the care to the client. The rendering provider, (Physicians, Physician Assistant, Nurse Practitioner, Affiliated Practice Dental Hygienist, et al), must bill with their own NPI number. In the case where a substitute or covering provider is used, that individual is considered the rendering provider. Bill with their own NPI in Box 24J Bill with modifier Q5 in Box 24D If the substitute provider is not a part of the practice, they should bill with their own Tax ID in Box 25. Locum Tenens A locum tenens arrangement is when a substitute physician is retained to take over a regular physician's professional practice for reasons such as illnesses, pregnancy, vacation or continuing medical education. The substitute physician generally has no practice of his/her own and moves from area to area as needed. The regular physician usually pays the substitute physician a fixed fee for service, with the substitute physician being an independent contractor rather than an employee. Substitute physicians are generally called locum tenens physicians. The patient's regular physician may submit a claim for covered visit services of a locum tenens physician who is not an employee of the regular physician and whose services for patients of the regular physician are not restricted to the regular physician's offices, if: the regular physician is unavailable to provide the visit services, the beneficiary has arranged or seeks to receive the visit services from the regular physician, the regular physician pays the locum tenens for his services on a per diem or similar feefor-time basis, Page G - 3

the substitute physician does not provide the visit services to patients over a continuous period of more than 60 days, and bill with modifier Q6 in Box 24D The patient s regular physician must keep on file a record of each service provided by the substitute physician, along with the substitute physician s NPI. This record should be available to Health Plan on request. It is not necessary to provide this information on the claim form. Scanning Recommendations & Tips Optical character recognition (OCR) is utilized when processing claims. It is extremely important that the name matches our records in order for the system to correctly identify the pay-to information. Failure to have the correct name on your claim may delay payment. Printing claims on a laser printer will create the best possible character quality If a dot matrix printer must be used, please change the ribbon regularly Courier 12 pitch non proportional font is best for clean scanning Recommend that all characters are printed in uppercase for optimal scanning Always attempt to ensure that clean character formation occurs when printing paper claims (i.e. one side of the letter/number is not lighter/darker than the other side of the letter/number) Please ensure that the claim form is lined up properly within the printer prior to printing Please make every effort to not place additional stamps on the claim such as received dates, sent dates, medical records attached, resubmission, etc. (characters on the claim form outside of the lined boxes have a tendency to throw off the registration of the characters within a box) Use an original claim form as opposed to a copied claim form as much as possible Use a standard claim form as opposed to a form of your own creation. (individually created forms have a tendency to not line up correctly, prohibiting the claim from scanning cleanly) The billing, servicing and/or rendering provider s NPI must be included in the locations listed below for accurate matching within the scanning and claim system. CMS 1500 (08/05) CLAIM FORM Diagnosis Codes In compliance with CMS guidelines, diagnosis codes that require a 4 th or 5 th digit will be denied if not submitted with appropriate specificity. Harbor Advantage never changes or alters a claim form. Required CMS 1500 (08/05) Fields The required fields to be completed on a CMS 1500 (08/05) claim form are as follows: BOX DESCRIPTION BOX DESCRIPTION 1a Insurer s I.D. Number 17b NPI Number 2 Patient s Name (Last, First, Middle Initial) 21 Diagnosis or Nature of Illness or Injury 1, 2, 3, 4 3 Patient s Birth Date/Sex 23 Prior Authorization Number 5 Patient s Address 24A Date(s) of Service 9 Other Insurer s Name (Last, First, Middle Initial) 24B Place of Service 9a Other Insurer s Policy or Group Number 24D Procedures, Service or Supplies Page G - 4

9b Other Insurer s Date of Birth/Sex 24F Charges (usual and customary amount(s)) 9c Employer s Name or School Name 24G Units 9d Insurance Plan Name or Program Name 24J Rendering Provider NPI Number (field required) 10 Patient s Condition Related to: a, b, c 25 Federal Tax ID Number or Social Security Number 12 Patient s or Authorized Person s Signature 28 Total Charge 13 Insurer s or Authorized Person s Signature 31 Signature of Physician or Supplier and Provider Identification Number 14 Date of Current Illness; Injury; Pregnancy 32 Name and Address of Facility Where Services were rendered Provider s Facility Name, Supplier s 17 Billing Name (as registered with the IRS), Name of Referring Physician or Other 33 Address, Zip Code and Phone Number. Source UPIN/NPI, Harbor Advantage Group ID Number. 17a Other ID Number 33a Facility/Legal Entity NPI number (field required) UB-04 CLAIM FORM In order to facilitate processing, the provider is required to return to Harbor Advantage the UB-04 claim form as follows: Claim forms are to be separated from each other. All data elements must be entered for the applicable fields, including but not limited to the discharge hour and patient status. Only CMS approved revenue codes will be reimbursable by Harbor Advantage. Diagnosis Codes In compliance with CMS guidelines, diagnosis codes that require a 4 th or 5 th digit will be denied if not submitted with appropriate specificity. Harbor Advantage never changes or alters a claim form. Required UB-04 Fields The required fields to be completed on a UB-04 Claim Form are as follows: BOX DESCRIPTION BOX DESCRIPTION 1 Provider Name, Address, and Phone Number 46 Service Units 3b Medical Record Number 47 Total Charges by Revenue Code 4 Bill Type 50 Payer 5 Federal Tax Number 51 UPIN Number and Harbor Advantage Group Number 6 Statement Covers Period 52 Release of Information 9 Patient Name 56 NPI Number (field required) 9 Patient Address 58 Insurer s Name 10 Patient Date of Birth 59 Patient s Relationship to Insured Page G - 5

11 Patient Sex 60 Patient I.D. Number 12 Admission Date 61 Group Name 13 Admission Hour 62 Insurance Group Number 14 Type of Admission 63 Treatment Authorization Codes 15 Source of Admission (Inpatient only) 65 Employer Name 16 Discharge Hour (Inpatient only) 66 Other Diagnosis Codes 17 Patient Status (Inpatient only) 69 Admitting Diagnosis Codes 19-28 Condition Codes 74 Principal Procedure Code and Dates 42 Revenue Code 74a-e Other Procedure Codes 43 Revenue Code Description 76 Attending Physician ID Number 44 HCPCS/Rates 77 Operating Physician ID Number 45 Service Date 78-79 Other Physician ID Numbers MODIFIERS Appropriate modifiers should be used when submitting claims to Harbor Advantage. Claims that are submitted with an inappropriate or missing modifier may be denied. Other Injections J3490 (unclassified drug code) requires a description & dosage and should only be used if there is no other appropriate code and requires prior authorization. HOSPITAL OUTPATIENT BILLING Hospital Outpatient Facility The UB-04 Claim Form must be used to list all services by revenue codes. All claims must be submitted with an itemized bill unless traditional Medicare is primary. Revenue codes must be approved for use by CMS in order for Harbor Advantage to reimburse. Check with CMS for valid revenue codes. Professional Fees (ER Physicians) Emergency room physicians professional fees must be submitted on a CMS 1500 form using the current CPT codes. THIRD PARTY LIABILITY When a patient has any insurance other than Harbor Advantage, the primary insurance company must be billed. Coordination of Benefits Prior authorization requirements apply to all members regardless of whether or not Harbor Advantage is primary or secondary. Page G - 6

All Harbor Advantage members are required to see contracted providers. If the member has primary coverage other than Harbor Advantage and the physician is not a Harbor Advantage contracted provider, services must be prior authorized in order to be paid. If a member has other insurance coverage, the physician agrees to identify and seek such payment before submitting claims to Harbor Advantage. Each provider shall include a complete copy of the other insurance carrier s EOB when submitting a claim for the balance due. A claim for any balance due must be received by Harbor Advantage within sixty (60) days from date of remit from the primary carrier or 180 days from date of service, whichever is greater. The allowed amount shall be based upon the lesser of Harbor Advantage s fee schedule or third party carrier s fee schedule, less the paid amount by the third-party carrier(s); any remaining balance shall be paid by Harbor Advantage as coordination of benefits. When billing for services denied by the primary carrier, the EOB must include a written description of the denial code. EOB s received without this information will be denied for a complete EOB. Worker s Compensation Any illness or injury covered under the Worker s Compensation or Occupational Disease Laws should be billed directly to the employer s insurance carrier in accordance with all state and federal laws. Motor Vehicle Accident/Trauma If a member requires services as a result of an accident (i.e., auto, motorcycle, etc.), please notify Harbor Advantage and provide the following information: Date of accident County where injuries were sustained Date(s) of hospitalizations and outpatient services Plan ID Number Name of any other insurance company Address and telephone number of member Address and telephone number of the member s attorney EXPLANATION OF REMITTANCE ADVICE (RA) The RA displays payment information including claim number, the patient s name and account number, the bill type and amount, a description of the services provided by the facility. The remittance advice is subject to change at Harbor Advantage s discretion. The following key fields are included on the Remittance Advice Report: Provider (Group) Number: Group ID number Member: Member Name Harbor Advantage s Member ID number Claim Date: Date of Admission/Service Form No.: Claim Number Page G - 7

Bill Type: Inpatient/Outpatient for UB04 or Void Status for DUPLICATE, ORGINAL, REPLACEMENT, or VOID This will be BLANK for CMS 1500 claim remittances Prov Acct: Patient s Account Number or, if Member is NOT on the Plan, their name will appear From Date: Begin Service Date Proc Code: Code Value (CPT Code) Billed Amount: The charges being submitted Allowed: Allowed Amount (includes both FFS and Capitation amount) Discount: Difference between Billed & Allowed CoPay/Coins: Co-payment or coinsurance. The Member is responsible for this amount. Deductible: The Member is responsible for this amount. Not Covered: Amount Pending/Denied Net Amount: Plan Liability (capitated services will show as zero dollars Expl Code: Reasons Pending/Denied Vendor Subtotal: Check Total Remit Total: Refunds, Voids, Payouts, Recoveries, and Voided Checks CLAIMS RESUBMISSION POLICY Providers may resubmit claims that have been adjudicated by Harbor Advantage within twelve (12) months of the date of service. Harbor Advantage will re-adjudicate claims re-submitted by providers only if an initial claim had been filed within the original prescribed submission deadline of 180 days from the date of service from a contracted provider. Claim forms should clearly indicate resubmission. To avoid duplicate claims, resubmissions of claims should be at least 60 days following the original claims submission. This will allow adequate time for Harbor Advantage to adjudicate the claim and have the check issued, mailed and posted by your staff. DUPLICATE OR ERRONEOUS PAYMENTS Providers should notify, in writing, any payment incorrectly collected from Harbor Advantage for services for which another carrier or entity has or should have primary responsibility. In the event of any overpayment, erroneous payment, duplicate payments or other payment of an amount in excess of which the provider is entitled, Harbor Advantage may, in addition to any other remedy, recover the same by offsetting the amount overpaid against current and future reimbursements due to the provider. CLAIM APPEALS PROCESS (RECONSIDERATION/RE-DETERMINATION) Claims Customer Services Harbor Advantage encourages providers to contact Claims Customer Service at (855) 343-9243 for assistance with questions or issues surrounding claim payment, partial payment, or non-payment. A noncontracted provider may dispute any claim payment, payment reduction or claim denial, by filing reconsideration. Page G - 8

Reconsideration If you would like to file a reconsideration request, such as in response to a claim payment, payment reduction or claim denial by Harbor Advantage, please submit the request in writing within 60 days from the date of the remittance advice or notice of adverse action. Be sure to include a cover letter explaining the basis for the appeal along with any required documentation to support the request, such as medical records. Failure to timely request an appeal is deemed a waiver of all rights to review. Providers may submit appeal requests by mail to: Harbor Advantage (HMO) Appeals & Grievances 7878 North 16 th Street, Suite 105 Phoenix, Arizona 85020 Or fax requests to Harbor Advantage at: 1-602-674-6673 Harbor Advantage acknowledges any reconsideration request received within five (5) business days of receipt. The appeal is reviewed and a decision rendered within 30 days of receipt. Harbor Advantage may request an extension of up to 14 days, if needed. If Harbor Advantage approves the reconsideration request, the provider receives a corrected payment and remittance advice. However, if Harbor Advantage upholds its original decision (e.g. denial) on any claim for medical services, you may request a retrospective appeal through the CMS designated Independent Review Entity (IRE). The IRE is contracted with the federal government and is not part of Harbor Advantage. Provider Appealing on Behalf of a Member If Harbor Advantage denies services for a member in whole or part, a provider can file an appeal on behalf of a member within 60 days of the original denial notice. A provider who elects to use this option needs to complete an Appointment of Representative form (AOR) as required by CMS. For a copy of the AOR form (go to the Forms and Attachments Section of the Manual) or to print and/or download the form, go to our website at: https://www.harborhealthadvantage.com/media/default/documents/members/grievance/m%20- %2017%20Appointment%20of%20Representative.pdf or CMS at: http://www.cms.hhs.gov/cmsforms/downloads/cms1696.pdf. The AOR must be signed by both the provider and the member and must accompany the appeal request. Send completed AOR forms to the Harbor Advantage mailing address and/or fax number. Completion of an AOR allows the provider to act on the member s behalf during the appeal process. The provider has all of the rights and responsibilities of an enrollee, or party, in obtaining an organization determination or in dealing with any of the levels of the appeal process. MEDICAL REVIEW OF CLAIMS Certain types of claims are subject to medical review prior to completion of processing. Page G - 9

The following types of claims may go through medical review. This list is not all-inclusive, and may be subject to change. Authorization number or description does not match billed services Multiple surgeries Out-of-area hospital services Services are reviewed by OaRS, a clinically based computer software program. OaRS supports Harbor Advantage in processing claims in a consistent and prudent manner. OaRS supports claims review by applying appropriate coding criteria as outlined by the American Medical Association's CPT-4 manual. OaRS was developed by physicians and health care experts and is annually updated and enhanced to remain current with technology and accepted medical practice. Harbor Advantage utilizes the Current Procedural Terminology (CPT) and the 1997 E & M Documentation guidelines for Evaluation and Management (E & M) services. Certain services require prior authorization. Please refer to the current applicable Prior Authorization Guidelines. Covering Physicians Physicians covering for a PCP are paid at the same rate of the PCP asking for coverage. Healthcare Practitioners (CNM s, CRNA s, NP s, PA s, etc.) Employed Certified Nurse Midwife (CNM), Certified Registered Nurse Anesthetists (CRNA), Nurse Practitioner (NP) & Physician Assistants (PA) are reimbursed at a percentage of the regular physician s fee schedule as outlined in the provider contract. Please notify Provider Services whenever a new health practitioner joins the practice. Services performed by a contracted health practitioner must be billed with the health practitioner s name in box 31 and NPI in box 24J on the CMS 1500 form. SURGERY CLAIMS Anesthesia Services performed by anesthesiologists do not require an authorization. Consultation or other evaluation and management codes on the same day as an anesthesia administration are not payable. If the consult or Evaluation/Management is the day before the anesthesia, then they are payable with an authorization. There is no additional reimbursement for age, physical status or unusual risk factors. Time units are determined on the basis of one time unit for each 15 minutes of anesthesia. Providers should report the total anesthesia time in minutes on the claim. Harbor Advantage will convert the total minutes to time units. Since only the actual time of a fractional time unit is recognized, Harbor Advantage will round the time unit to one decimal. NOTE: Time units are not recognized for codes 01995 (regional IV administration of local anesthetic agent upper or lower extremity) and 01996 Page G - 10

(daily management of epidural or subarachnoid drug administration). Bilateral Procedures Indicate by billing with modifier 50. The charges should be combined and entered with a unit value of 1 on a single line. Charges must be entered on one line with modifier 50. Example: Line one = 69436 50, dollar amount with 1 unit. (150% of fee schedule) Multiple Surgery Guidelines Multiple procedures are paid at 100% of the applicable fee schedule for the first procedure, and 50% of the applicable fee schedule for the next five procedures. OP reports are required for all multiple procedures. CLAIMS SUBMITTED BY INPATIENT FACILTIES Claims for inpatient facilities must be billed on a UB-04 claim form. Payment will be based on the traditional Medicare Prospective Payment system utilizing Diagnosis Related Group (DRG) Based Prospective Payment Systems (PPS) and your contracted rate. Discharge hour is required for inpatient claims except for interim bill type 112, 113, 122 and 123. All UB-04 bills must have an itemized statement attached unless insurance is primary. OUTPATIENT FACILITIES Outpatient facility services must be billed on a UB-04 Claim Form. Payment for outpatient facilities will be based on traditional Medicare s outpatient PPS utilizing Ambulatory Payment Classification s (APC s) and your contracted rate. Bill type should be 13x. All UB-04 s are required to have an itemization attached. Charges for hospital outpatient services that result in a direct admission to the hospital must be included on the inpatient UB-04 claim. If the member is discharged from the ER, observation room, or other outpatient department and then is subsequently admitted, the hospital should submit separate claims. To enable Harbor Advantage to distinguish inpatient and outpatient UB-04 claims for the same member for the same date of service, hospitals must include the admit hour and discharge hour on both the outpatient and inpatient claim. Air Transportation charges are not accepted on a UB-04 form. All professional fees must be billed on a CMS 1500 Claim form. ANCILLARY CLAIMS Dialysis Page G - 11

Harbor Advantage utilizes traditional Medicare guidelines when processing ESRD services. Durable Medical Equipment Harbor Advantage maintains contracts for all DME services. Equipment not provided by our contracted vendor(s) may require prior authorization. Home Health All services not provided by our contracted vendor require prior authorization including services rendered to members where Harbor Advantage is secondary. Hospice Harbor Advantage is not responsible for any claims regardless of the diagnosis, in any month that the member is deemed a hospice beneficiary by traditional Medicare. Claim forms should be sent to traditional Medicare for payment. Laboratory PCP s and specialists may bill certain CPT codes and receive reimbursement. Please refer to Section F for additional information. Radiology Providers must bill with the correct modifier (26 for professional or TC for technical) if billing for other than the global service. Diagnosis code 799.9 is invalid for radiology services. Harbor Advantage requires at least one valid diagnosis. Skilled Nursing Facilities Harbor Advantage has developed case rates based on the level of care provided during a specific length of stay. Level of care is determined by the case manager assigned to the skilled nursing facility. Please check with the prior authorization unit if you are not certain what level of care has been assigned. Type of bill must be 21x Admit and discharge hour is required. Services must be billed on a monthly basis only. Claims with overlapping service months will be denied with instruction to resubmit with corrected dates. When a member is admitted to an acute care facility and returns to the skilled nursing facility, the bill must be split to reflect that the member was transferred and readmitted to the skilled nursing facility. The patient status must reflect that the member was transferred, including the discharge hour. Page G - 12

Revenue Codes Allowed Bill Type(s) 190 Custodial 86X 191 Level I 110 179, 211 228, 611-628 192 Level II 110 179, 211 228, 611-628 193 Level III 110 179, 211 228, 611-628 194 Level IV 110 179, 211 228, 611-628 199 Vent/Dialysis 651-678 EMERGENCY TRANSPORTATION Supplies are to be billed by the ambulance service and not the supply company. No authorization is required for emergency transportation. The pick up point and destination is required. A trip ticket or a notation on the claim form is sufficient. Ambulance wait time is included in the base rate and is not a separately identifiable service unless the waiting time is excessively long and constitutes unusual circumstances. The claim must completely document why the ambulance was required to wait and the exact amount of time involved. Use HCPCS code A0420 to bill this service. The first half hour is included in the base rate. GENERAL INFORMATION Critical Care Codes Critical Care 99291 is payable for the first hour. Code 99292 (additional ½ hour) may be payable with documentation (medical notes) and time, if deemed appropriate by Harbor Advantage. The total time spent with the member must be noted in the medical record. CMS 1500 (08/05) Box 31 and 33 Box 33 should always indicate the entity name as provided to the IRS, CMS, and Harbor Adsvantage. When box 31 on the CMS 1500 (08/05) form has Signature on File, Harbor Advantage will accept this as long as the processor can determine the servicing provider. If only the group name appears in box 33 and the processor is unable to determine the servicing provider, the claim may be denied. If the same service is performed on the same day and by the same provider, documentation must support it. If a claim is received with dates of service that fall after the received date the entire claim may be denied. Diagnosis codes that require a 4 th or 5 th digit may be denied if not submitted with appropriate code. Harbor Advantage never changes or alters a diagnosis code. CPT codes 99050, 99051, 99053, and 99058 are considered bundled and no additional separate payment will be made. Members cannot be billed for copying medical records, completing any type of form(s), or noshow appointment. Page G - 13

Members requesting non-covered services must sign a detailed consent form or Advance Beneficiary Notice (ABN) prior to receiving non-covered services. The consent form must be reviewed prior to rendering the service and must be easy for the member to understand. The form must include the exact cost to the member of the service (non-covered benefit). The consent form must ask the member if they understand the procedure is not covered by their insurance and if they understand they will be charged for the services provided. General forms signed at a member s first visit are not considered written consent by Harbor Advantage. A copy of this form and instructions for use can be found on the following website: Ø http://www.cms.gov/medicare/medicare-general-information/bni/abn.html Page G - 14