PROVIDER RESOURCE / MEDICARE ABN

Medicare ABN
2026 update.

Current form requirements and practical steps for physician practices

By Donnine Day, BS, CPC, CPMA, CRC, CVBC, CEMC, CENTC, CGSC

Published and reviewed October 20, 2026 · For physicians and APPs

The updated Advance Beneficiary Notice of Noncoverage, Form CMS-R-131, became mandatory on May 12, 2026. Use the version that expires March 31, 2029. Check electronic templates and printed stock. A signature alone does not establish a valid notice or permit patient billing. [1][2]

Use the current form

The revised ABN uses plainer language and updated formatting. CMS provides English and Spanish forms, including large-print versions. Download them from the official CMS ABN page rather than recreating the form or relying on an old saved copy. [2][5]

Confirm CMS-R-131 and the March 31, 2029 expiration date on the form. [1]
Replace outdated EHR templates, billing-system copies, and printed forms.
Review the current instructions with front-desk, clinical, and billing staff.

Know when an ABN is needed

For Original Medicare, issue a required ABN before a normally covered service when there is a specific reason to expect denial under the applicable notice rules. Examples include an expected medical-necessity denial under an LCD or a service that exceeds a coverage frequency limit. [3]

CMS-R-131 is not the notice for Medicare Advantage or Part D services. Items Medicare never covers generally do not require a mandatory ABN; a voluntary notice may be appropriate. Do not treat every noncovered service as a GA or GZ situation. [3][4]

Make the notice clear before the service

Identify the specific item or service and explain the expected reason for noncoverage in patient-friendly language.
Provide a good-faith cost estimate and complete the applicable form fields.
Explain the notice and allow enough time for an informed decision before care is provided.
Obtain the patient's or representative's choice, signature, and date when required. Keep the completed notice and provide a copy on request. [2]

Do not use a blanket ABN for every visit or obtain it under coercion, during a medical emergency, or under great duress. A late notice cannot retroactively shift liability for care already provided. [6]

Match modifiers to coverage and notice status

For applicable Medicare claims, choose the modifier that reflects the actual reason for noncoverage and the notice issued. [4]

ABN claim modifier comparison
Modifier	When it applies	Practical implication
GA	Required ABN was issued and retained.	A valid notice is needed to support potential patient liability.
GZ	Expected denial as not reasonable and necessary; no ABN was issued.	The practice may be financially liable. GZ is not a substitute for a timely notice.
GY	Statutorily excluded or outside a Medicare benefit.	A mandatory ABN is generally not required.
GX	A voluntary notice was issued for a service Medicare never covers.	Apply CMS reporting instructions, including GY when appropriate.

Respect the patient's decision

For a required ABN, the patient or representative generally chooses one option. Do not preselect it for the patient except as CMS specifically instructs. [2]

Option 1: Receive the service and have Medicare billed for an official decision, with Medicare appeal rights.
Option 2: Receive the service without billing Medicare; there is no Medicare claim decision to appeal.
Option 3: Decline the listed service. Do not charge for services not provided.

Dually eligible patients, including those with QMB or Medicaid coverage, require special CMS instructions for Option 1 and billing. Do not collect from them when the ABN is delivered; follow the required Medicare and Medicaid adjudication process and applicable billing protections. [2]

Check the workflow as well as the form

Assign responsibility for checking coverage before care, identifying the reason for a possible denial, delivering the notice, recording the patient's choice, and applying claim instructions. Review a small sample of completed ABNs to find gaps. An invalid required notice may leave the practice unable to collect from the patient after a denial. [4]

How MCRS can help

MCRS can review your ABN workflow and related documentation or coding education needs. Contact donnine@mcrsconsulting.com to discuss a focused review. Keep patient information out of your initial email.

References

Sources accessed October 20, 2026. This educational resource is not the official ABN form.

Educational information. Confirm current code-set, contract, and payer requirements for the date of service. This resource does not determine a claim outcome or guarantee payment.

Medicare ABN2026 update.