NOMNC Instructions for Skilled Nursing Facilities

The Centers for Medicare & Medicaid Services (CMS) requires that members enrolled in Medicare Advantage health plans, like Regence MedAdvantage, have the right to a fast track review by a Quality Improvement Organization (QIO) if they appeal the discontinuation of their skilled nursing facility coverage.

It is imperative that your organization understands that Medicare requires the Notice of Medicare Non-Coverage (NOMNC) form to be issued for every planned discontinuation of Skilled Nursing Facility (SNF) level of care. The NOMNC form informs the member of the date that the member is no longer eligible for SNF level of care. The NOMNC form describes the member’s appeal rights if they disagree with that decision.

Discharge planning is an ongoing process, occurring throughout the SNF stay. When the decision is made that the member is approaching the time when CMS criteria for SNF level of care will no longer be met, the SNF should prepare to issue the NOMNC. By issuing the NOMNC in accordance with CMS timeframes, the member has two additional days paid by Regence MedAdvantage to finalize discharge plans. If the member wants to appeal that decision, the member may file an appeal with the QIO by noon of the day following issuance of the NOMNC.

The NOMNC process
The following information highlights the process that Regence MedAdvantage participating facilities must follow. It also lists resources for additional information and gives a sample case scenario. 

1. The last day of covered SNF level care is identified and discussed with the patient and family or authorized representative.
2. SNF selects the Regence SNF NOMNC form. Be sure to select the correct version of the form. Versions vary by service area.

   Note: The name, address and telephone number of the provider that delivers the notice must appear above the title of the form.

3. The patient or authorized representative signs the NOMNC form. If the patient is unable to sign, and the SNF is working with an authorized representative who is unable to be present at the facility that day, SNF may issue the NOMNC by telephone.

1. For a telephonic notice to be valid, the documentation must include the following: 
   • The name of the staff person initiating the contact
   • The name of the representative contacted by phone
   • The date and time of the telephone contact
   • The telephone number called
   • A notation that full appeal rights were given to the representative

   The date of the properly documented telephone conversation is the date of the receipt of the notice. The facility must confirm the telephone contact by written notice mailed on that same date.

4. Copies of the completed NOMNC are
   1. given to the patient or the authorized representative who signed the NOMNC
   2. placed in the patient’s medical record at the SNF
   3. faxed to Regence at 1 (800) 453-4341
5. A NOMNC must be issued a minimum of 48 hours or 2 days prior to the last day the patient is anticipated to be at SNF level of care. However, NOMNCs can be issued earlier to accommodate a weekend or to provide a longer transition period.
6. The patient may choose to discharge sooner than the designated day.
7. If the patient chooses to appeal, the patient must contact the QIO to request a review no later than noon on the day before services are to end. The QIO appeal decision will generally be completed within 48 hours of the patient's request for a review.
8. Contact your provider consultant or Regence MedAdvantage Provider Customer Service if you have additional questions.

Where to find additional information:

• CMS requirement #42 CFR 422.624(b) (2) can be found as a final rule published in the April 4, 2003 edition of the Federal Register, Vol. #68, No. #16652.
• CMS provides detailed explanations of the appeal process, along with frequently asked questions, on their Web site.
• Contact your provider consultant or Regence MedAdvantage Provider Customer Service if you have additional questions.

Skilled Nursing Facility sample scenario:
On May 25th, Jane Doe is admitted to a SNF after surgery. On June 2nd, Regence MedAdvantage contacts the SNF to deliver a Regence NOMNC form to Ms. Doe indicating her last approved day will be June 4th, with discharge to a lower level of care on June 5th. 

Revised October 2011