Failure to Timely Provide NOMNC Form
Penalty
Summary
The facility failed to provide the Notice of Medicare Non-Coverage (NOMNC) form to the representative of a resident, identified as Resident 32, within the required timeframe. Resident 32 was admitted with diagnoses including unspecified dementia, cerebrovascular accident, and dysphagia. The Minimum Data Set (MDS) assessment indicated that Resident 32 had moderately impaired cognitive skills and required assistance with daily activities. The Business Office Manager (BOM) acknowledged that the NOMNC form was given to the resident's representative only one day before the end of Medicare Part A skilled services, instead of the required 48 to 72 hours prior. The facility's policy, titled Medicare Denial Process, mandates that the NOMNC form be delivered at least two calendar days before the end of Medicare-covered services. However, the BOM admitted that the form was provided late, which deprived the resident's representative of the opportunity to appeal the decision regarding financial coverage for continued skilled care services. This oversight had the potential to result in the resident unknowingly incurring expenses for non-covered care.
Plan Of Correction
How corrective actions will be accomplished for those residents found to have been affected by this deficient practice: On 3/10/25 the Business Office Manager (BOM) contacted the responsible party for Resident 52 and issued the Notice of Medicare Non-Coverage (NOMNC) with the correct dates of the last covered day and first non-covered day for Resident 52. Resident 52's responsible party verbalized understanding and did not have any further questions or concerns at that time. How the facility will identify other residents, having the potential to be affected by the same deficient practice and what corrective action will be taken: All residents have the potential to be affected by this deficient practice. On 3/10/25 the Administrator conducted an audit of active residents who received a NOMNC within the last six months. No other residents were affected by this deficient practice. What measures will be into place or what systemic changes the facility will make to ensure that the deficient practice is not recur: On 3/10/25 the Administrator in-serviced the Business Office Manager on the facility's policy and procedure titled, "Medicare Denial Process," with emphasis on delivering the NOMNC at least two calendar days before Medicare covered services end or the second to last day of services if care is not being provided daily as referenced in the NOMNC instructions (CMS-10123). The Administrator will conduct audits on residents who are receiving NOMNCs daily for 5 days, weekly for 2 weeks, and monthly thereafter to ensure that NOMNCs are being provided at least two calendar days before Medicare coverage services end or the second to last day of services if care is not being provided daily. How the facility plans to monitor its performance to make sure that solutions are maintained: The Administrator will report to the Quality Assessment and Assurance committee during its monthly meeting the status of the compliance for NOMNC given to residents for three months or until compliance is met.