Failure to Provide SNF ABN Notice When Medicare Coverage Ended
Penalty
Summary
The facility failed to provide a written notice of financial liability, specifically the Skilled Nursing Facility Advance Beneficiary Notice (SNF ABN), to two residents when their Medicare Part A coverage ended and they chose to continue receiving skilled nursing services. For one resident, records showed severe cognitive impairment and a need for substantial assistance with daily activities, while another resident had moderate cognitive impairment and was entirely dependent on staff for several activities of daily living. Both residents remained in the facility after their Medicare Part A coverage ended, but did not receive the required SNF ABN form informing them of potential financial responsibility for non-covered services. During interviews, the Business Office Manager (BOM) acknowledged that the SNF ABN form should have been provided to these residents but was not, due to a misunderstanding of an email from corporate which led her to believe the SNF ABN had been replaced by the Detailed Explanation of Non-Coverage (DENC) form. As a result, the BOM had not provided the SNF ABN form to any residents since January of that year. Facility policy required that residents be informed in advance of changes to their billing and potential liability for non-covered services, but this procedure was not followed in these cases.