Failure to Issue Required Medicare Non-Coverage Notices
Penalty
Summary
The facility failed to provide the required Notice of Medicare Non-Coverage (NOMNC), Form CMS-10123, to two residents who were ending their Medicare Part A skilled services after meeting their therapy goals and returning to baseline independence. In both cases, the residents received the Skilled Nursing Facility Advance Beneficiary Notice of Non-Coverage (SNF ABN), Form 10055, but not the NOMNC, which is mandated to inform beneficiaries that Medicare coverage is ending and to provide information on how to appeal the decision. Documentation reviews confirmed that the NOMNC was not issued, and staff indicated they were unaware that both forms were required. Interviews with the Social Worker revealed confusion regarding the correct forms to use, as she had only completed the SNF ABN and was not properly trained on the NOMNC process. The Social Worker began handling beneficiary notifications when the MDS Coordinator went on leave and acknowledged insufficient training from the previous Administrator. The Administrator was unaware of the error until it was brought to their attention, and the Nurse Consultant confirmed that the facility did not have a policy in place regarding beneficiary notifications.