CMS approved an updated CMS-R-131 — the Advance Beneficiary Notice of Noncoverage — on March 13, 2026. The form number is unchanged. The content requirements are the same. The readability and formatting have been improved. The transition deadline is May 12, 2026.
After May 12, the previous version of the form is expired. A practice that delivers a non-covered Medicare service to a beneficiary using an outdated ABN cannot bill the patient and forfeits the revenue permanently.
This is an administrative update, not a compliance overhaul. But the penalty for non-compliance is the same regardless of cause — a practice that issues an invalid ABN because it forgot to update its template faces identical revenue forfeiture to one that issued no ABN at all.
Most practices have ABN templates embedded in front desk workflows, patient intake systems, or EHR documentation. Those templates need to be updated before May 12. The updated CMS-R-131 is available at no cost at cms.gov — download it, replace your templates, and document the change date.
CMS has signaled intent to issue further guidance on ABN delivery requirements for telehealth encounters — specifically around audio-only contexts where document exchange is less standardized. Practices that bill Medicare telehealth should watch for that guidance in the second half of 2026.
For the complete ABN compliance framework — mandatory vs. voluntary, field-by-field CMS-R-131 requirements, penalty risk audit, and a ready-to-use template — see the Medicare ABN Compliance Playbook.
The One Big Beautiful Bill Act — moving through Congress as of publication — proposes Medicaid work requirements, more frequent eligibility redeterminations, restrictions on state Medicaid financing mechanisms, and removal of enhanced federal matching funds. The Congressional Budget Office projects 11.8 to 17 million Americans losing Medicaid coverage over the next several years under the provisions as written.
The coverage disruption will not arrive as a headline. It will arrive as a pattern in your daily eligibility verification runs. A patient who was Medicaid-enrolled at their last appointment will return with inactive coverage and no explanation. Front desk staff will handle it inconsistently — some patients seen and billed at self-pay rates they cannot pay, some billed to an inactive plan with a deny arriving 45 days later.
The practices most exposed are those serving high Medicaid-volume populations without a structured financial counseling workflow. Collection rates on self-pay balances are three to four times higher when the financial conversation happens before service than after. Build that workflow before the disruption arrives.
State-level Medicaid redetermination timelines are the leading indicator of when your patient panel starts showing coverage disruption. The federal bill sets the policy — states determine the pace. Track your state's implementation calendar and watch for the pattern in your daily eligibility verification runs before it shows up in your AR.
UnitedHealthcare — the largest Medicare Advantage insurer, with approximately 10 million MA enrollees — reported catastrophic medical cost overruns in 2025, issued multiple downward earnings revisions, and replaced its CEO. The underlying cause is not UHC-specific: MA plans industry-wide competed aggressively for enrollment with supplemental benefits that attracted sicker, higher-utilizing members than actuarial assumptions anticipated. When utilization runs high, plans face a constrained set of responses — raise premiums, cut benefits, tighten coverage, exit markets — or all four.
Every one of those responses eventually reaches the provider. Tighter coverage policies show up as increased prior authorization requirements and higher denial rates on codes previously paying cleanly. Market exits — which are accelerating in 2026 — create network instability that is the sleeper risk most practices are not monitoring.
When an MA plan exits a market or restructures its network, it does not always communicate the change to contracted providers. A practice may bill claims as in-network while the plan adjudicates them as out-of-network. The difference in reimbursement can be 40 to 60 percent of contracted rate — and by the time billing staff identify the pattern, months of claims are underpaid.
Verify your network participation status with every Medicare Advantage plan you bill — not annually, quarterly. Pull your MA denial rate by payer and by denial reason code for the last 90 days. A pattern of increasing denials on codes previously paying cleanly is your early warning signal. The 2027 benefit filing cycle will determine whether further plan exits follow this year's restructuring.