Medicare Part A typically covers care at comprehensive outpatient rehabilitation facilities, skilled nursing facilities, home health agencies, and hospices. For such services to be covered, Medicare must deem the services to be medically reasonable and necessary. When medical care no longer meets Medicare requirements for coverage (which, generally, is when the individual has reached their maximum improvement) the facility must provide a Notice of Medicare Non-Coverage (NOMNC) to the patient. This notice informs the patient that Medicare will not cover their care on a certain date, and if they would like to continue care, they will assume financial responsibility. The notice must be delivered at least 48 hours before the last date of coverage.
When the NOMNC is required:
- When the provider’s coverage of services is ending and the patient is staying in the facility.
- When the patient will be discharged or transferred to a lower level of care, such as going from a skilled nursing facility to assisted living or their home.
When the NOMNC is NOT required:
- When the patient decides to end coverage.
- When the patient is close to meeting their allowed days under Medicare Part A. For example, when you reach your allowed 100 days of care in a skilled nursing facility.
- When the patient is transferred to another facility.
As mentioned above, the NOMNC must be given to the patient or patient’s representative at least two calendar days before coverage ends. The NOMNC also requires a signature to acknowledge receipt of the NOMNC and allows the patient to request an expedited appeal of their termination of coverage.
If you believe the level of care is still necessary, you may appeal to the Beneficiary and Family Centered Care-Quality Improvement Organization (BFCC-QIO) listed on the NOMNC and request an expedited review. Or you may call 1-800-MEDICARE to contact your local BFCC-QIO. The provider oftentimes will file an expedited appeal on the patient’s behalf because the medical record is required as part of the appeal. The patient and/or family also have the opportunity to include a letter outlining their reasons as to why they feel the patient still requires the care they are receiving. Once the appeal is submitted, the turnaround time is not longer than 48 hours after care is set to end.
If the termination of coverage is upheld, the patient has several additional levels of appeal. The patient must be aware though that if the termination decision isn’t overturned that they are responsible for the provider’s charges from the date of the NOMNC. However, no bills are issued to the patient during the appeal process.
The guidelines of a NOMNC are standardized and applied to both Medicare and Medicare Advantage plans. The full details can be found here.
Learn More:
Medicare Denial Letter: What to do Next | Healthline
NOMNC Instructions | Kepro
Last Revised June 5, 2023
