Failure to Issue Advance Beneficiary Notices for Non-Covered Services
Penalty
Summary
The facility failed to provide required Advance Beneficiary Notice (ABN) forms to residents whose Medicare Part A coverage was ending, as observed in three cases reviewed. In each instance, the residents were given a Notice of Medicare Non-Coverage (NOMNC) form indicating the last covered day of Medicare services, but there was no documentation that the ABN form was provided. Facility records confirmed that while the NOMNC was issued, the ABN was not, even when residents transitioned to private pay or personal insurance after Medicare coverage ended. Interviews with facility staff revealed a lack of understanding and implementation regarding the ABN process. The Social Services Director and Memory Care Coordinator/Social Services were responsible for providing NOMNC forms but did not provide ABN forms, with one staff member unfamiliar with the ABN entirely. The Business Office Manager, who handled financial discussions with residents, also did not provide or document the ABN form. The facility's own policy required the use of the CMS-approved ABN form for Part A items and services, but this was not followed in the reviewed cases.