Failure to Provide Proper and Updated Medicare Coverage Notices
Penalty
Summary
The provider failed to ensure that proper Medicare notices were completed fully and in the required format for three sampled residents prior to their discharge from Medicare Part A skilled services. Specifically, the facility used outdated versions of the Notice of Medicare Non-Coverage (NOMNC) and Skilled Nursing Facility Advance Beneficiary Notice of Non-coverage (SNF ABN) forms, despite updated forms being mandated for use as of specific dates. The NOMNC forms did not specify the type of services ending, such as skilled nursing, and lacked required contact information for the Quality Improvement Organization (QIO), including the name and toll-free number. Additionally, the forms did not include all information required when notice was delivered by phone to a resident's representative, such as the last day of covered services, the date liability would begin, and details about the appeal process. The sampled residents included two who remained in the facility after their Medicare Part A coverage ended and one who was discharged home. Among these, two residents had severe cognitive impairment and one had moderate cognitive impairment, as indicated by their Brief Interview for Mental Status (BIMS) scores. The facility's social services designee (SSD) completed the forms and contacted the residents' representatives by phone, but failed to document all required information on the forms and did not mail annotated copies to the representatives as required. During an interview, the SSD acknowledged being unaware that the forms used were outdated and that new forms were required. The SSD also agreed that the forms were not fully completed according to instructions, including missing information about the type of services ending and the QIO contact details. The SSD was not aware of the specific documentation requirements for telephone notification to representatives, resulting in incomplete records for the residents affected.