Deficient Medicare Notice Practices and Incomplete Documentation
Penalty
Summary
The facility failed to provide proper Medicare notices to residents who were discharged from Medicare Part A skilled services and remained in the facility. For one resident, the Notice of Medicare Non-Coverage (NOMNC) form used was outdated and did not include the required non-discrimination clause. This was confirmed by the MDS/RN coordinator, who acknowledged the form was not current. For another resident, the NOMNC form was not signed or dated by the resident or their representative, as required by the form's instructions. Additionally, the Skilled Nursing Facility Advance Beneficiary Notice of Non-coverage (SNF ABN) for the same resident did not include a sufficient explanation in the "Reason Medicare May Not Pay" section, only stating "Custodial Care" without specifying the Medicare services being denied. There was also no documentation of who provided the verbal notification to the resident's representative. The MDS coordinator confirmed these omissions and was unable to identify who had given the verbal notice. Review of the relevant CMS form instructions confirmed that these elements were required for compliance.