ABN and NOMNC
Question and Answer Series
1. What is the Last Covered Day (LCD) that should be entered on the NOMNC for a patient not dually eligible for Part A and Hospice, who elects hospice?
The "Last Covered Day" on the NOMNC is always the last day Medicare A was billed for the services. It's never the first day of patient liability. The form says, “The effective date coverage of your current _________ services will end: ______________(insert effective date.) It then goes on to say, “You may have to pay for services after the above date.”
The ABN uses different language: “Beginning on _____ you may have to pay ….” For the ABN, you would use the first day AFTER the last covered day.
The NOMNC tells the patient they have a right to appeal our decision, and the ABN asks whether they want to continue services and whether they want the facility to do the demand bill.
A NOMNC is not issued when a patient elects to end their skilled day. If the patient elects to end their stay, the NOMNC isn't given.
Think of the potential liability for an unsafe discharge when the patient insists to go home even though the facility believes they still have a skilled need. We do not want to give this person who elected to leave a paper saying that we determined it was time to go home.
2. Is NOMNC required for Medicare Part B therapy?
Yes, the NOMNC must be provided to beneficiaries and/ or enrollees receiving Medicare Part B covered services, including but not limited to:
- skilled nursing,
- home health (including psychiatric home health),
- *comprehensive outpatient rehabilitation facility, and
- hospice services.
*The (CORF) is a medical facility that provides outpatient diagnostic, therapeutic, and restorative services for the rehabilitation of injury, disability, or illness.
CORF care is commonly known as outpatient rehabilitation care.
3. Do you still give the NOMNC with the SNF ABN if an SNF resident chooses hospice immediately and the facility is unable to give a 48-hour notice?
In this scenario, the patient is driving the end of the Medicare Part A coverage due to the election of hospice.
The SNF ABN is important to identify the financial liability as the patient comes off Medicare Part A and will be responsible for room and board.
The Hospice GIP benefit is brief and not all facilities can offer this service.
The lack of a 2-day notice is acceptable if the patient is making the determination and was not denied coverage by the facility.
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