A couple important reminders regarding the requirements for issuing Notices of Medicare Non-Coverage (NOMNC) and Discharge Notices. These two requirements are separate and cannot be used interchangeably.
Notice of Medicare Non-Coverage (NOMNC), Form CMS-10123
- The NOMNC form is provided to Medicare beneficiaries in skilled nursing facilities and informs them that their Medicare covered services are ending.
- Guidance from F581 includes:
- The NOMNC must be given to all Medicare beneficiaries at least two days before the end of a Medicare covered Part A stay or when all Part B therapies are ending. The NOMNC informs beneficiaries of their right to an expedited review by a Quality Improvement Organization. Note the following exceptions: the beneficiary exhausts the SNF benefits coverage (100 days), the beneficiary initiates the discharge from the SNF, or the beneficiary elects the hospice benefit or revokes the hospice benefit to return to standard Medicare coverage.
Discharge Notice
- The facility must permit each resident to remain in the facility, and not transfer or discharge the resident from the facility unless certain criteria are met, outlined in F627.
- The facility must notify the resident and the resident’s representative of the reasons for discharge and a copy of the discharge notice must be provided to the Ombudsman. (F628)
- Guidance from F628 includes:
- For residents discharged home after a Medicare Part A stay, the discharge notice must be provided along with the NOMNC. The NOMNC does not replace the requirement for a discharge notice.
- A discharge notice must be issued to residents regardless of the length of their stay. For example, if the resident is admitted for rehab and their Medicare Part A stay ends at 21 days, a discharge notice must still be issued. The notice must be issued “as soon as practicable” in this instance since the resident has not resided in the facility for more than 30 days.
The National Long-Term Care Ombudsman Resource Center has created a helpful resource for facilities highlighting the changes regarding Transfer and Discharge Notices, in Appendix PP that were effective April 25, 2025. We encourage facilities to review these requirements carefully and ensure that both the NOMNC and discharge notices are issued appropriately to comply with federal regulations and to protect the rights of residents.