Today is the day the old ABN form dies.
CMS updated the Advance Beneficiary Notice of Noncoverage — the CMS-R-131 — in March. The transition window was 60 days. That window closes today, May 12, 2026.
From this point forward, any practice delivering a non-covered Medicare service using the previous version of the form cannot bill the patient. The revenue is gone. Not delayed. Not appealable. Gone.
Here is what makes this particularly frustrating: the form itself did not change in any meaningful way. Same name. Same number. Same content requirements. CMS improved the readability and formatting — which is good for patients and practices alike. The update was not controversial. The content is not harder to comply with. The only thing that changed is the version, and the only thing required of practices is to swap the template.
Yet practices will lose revenue today because of an ABN form that expired in a filing cabinet.
What the ABN Actually Does
The Advance Beneficiary Notice exists to protect two things simultaneously: the patient's right to make an informed financial decision, and the practice's right to collect when Medicare denies.
When Medicare is likely to deny a service as not medically necessary, not covered, or otherwise excluded — the practice must notify the patient before delivering that service. The ABN explains what the service is, why Medicare may not pay, and what the patient's estimated cost will be. The patient signs. The practice delivers the service. When Medicare denies, the practice can bill the patient.
Without a valid ABN, that transaction disappears. The service was delivered. Medicare denied it. And the practice has no legal mechanism to collect from the patient.
The ABN is not optional paperwork. It is the legal foundation that makes patient billing possible when Medicare says no.
The Three Errors That Cost Practices Money
Error 1: Using the wrong form version. As of today, the previous CMS-R-131 is expired. If your front desk is still handing out the old version, every ABN issued from this point forward is invalid. The fix takes five minutes — download the updated form from cms.gov, replace the template in your system, and document the change date.
Error 2: Issuing it too late. The ABN must be presented before the service is delivered. Not after. Not at checkout. Before the patient is in the chair, on the table, or receiving the service. A signature obtained after the fact does not create valid financial liability. Courts and auditors have consistently held that the ABN's protective function depends entirely on the patient having a real opportunity to decide — and that opportunity must exist before service.
Error 3: Issuing it for the wrong services. ABNs apply to Medicare fee-for-service. They do not apply to Medicare Advantage. They cannot be used as a blanket waiver for any service the practice wants to avoid write-offs on. The ABN is a specific tool for a specific purpose — non-covered or likely-denied services under traditional Medicare — and misuse creates compliance exposure rather than financial protection.
What to Do Today
Three actions — right now, in order
If you haven't updated your template: Stop and do it now. The form is at cms.gov — search "CMS-R-131." Download the current version dated March 2026. Replace your template. Document the date you made the change.
If you have updated your template: Confirm it is in the hands of every staff member who issues ABNs — front desk, clinical staff, anyone who touches the moment before a potentially non-covered service is delivered.
Audit your exposure: Pull your Medicare claims from the last 90 days. Identify every service that was denied as not covered or not medically necessary. For each denial — was a valid ABN on file? If not, that revenue was unrecoverable regardless of whether you appealed. Understanding your exposure is the first step to closing it.
The ABN is not complicated. The process is not burdensome. The form is free. The compliance is achievable.
What costs practices is not the complexity — it is the assumption that someone else already handled it.
Verify today. Fix if needed. Document that you did.
For the complete ABN compliance framework — mandatory vs. voluntary issuance, field-by-field CMS-R-131 requirements, penalty risk audit, and a ready-to-use updated template — the Medicare ABN Compliance Playbook covers everything in one place.