The Office of Management and Budget (OMB) has approved a revised Notice of Medicare Non-Coverage (NOMNC/CMS-10123) and Detailed Explanation of Non-Coverage (DENC/CMS-10124). These updated forms are to be used for both traditional Medicare and Medicare Advantage plans. Some of the revisions are applicable only to the Medicare Advantage plans. Providers are to use the revised forms effective January 1, 2025 for Original Medicare. There has been an extended deadline to implement the DENC for Medicare Advantage.
The NOMNC has been revised to reflect regulations that now allow Medicare Advantage enrollees the right to appeal untimely to the Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO) or to appeal after they end services on or before the planned termination date.
Medicare Advantage plans have expressed concern with implementing the revised notices close to the start of the 2025 plan year, given the need for programming and testing activities. As a result of these concerns, CMS will allow Medicare Advantage plans additional time to implement the revised DENC but no later than April 1, 2025.
Skilled nursing facility providers are required to provide an NOMNC to beneficiaries when their Medicare services are ending. The NOMNC informs beneficiaries on how to request an expedited determination from their BFCC-QIO. A DENC is given only if a beneficiary requests an expedited determination.
The updated forms can be downloaded on the CMS site. If you have any questions or need assistance, please reach out to a professional at Forvis Mazars.