It really is starting off to be a busy regulatory year and we’re trying to keep up. As you may be aware, a significant announcement has been made by both Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO) organizations that service SNFs across the country, Kepro and Livanta.
These are the organizations that, among other things, facilitate the Expedited Determination process. That occurs when a beneficiary or their representative appeals a Medicare Non-Coverage/NOMNC, or Generic Notice. Check the websites to see which BFCC-QIO services your SNF.
In other words, when a resident or their representative disagree with a facility coverage decision, they must contact either Kepro or Livanta to appeal. The NOMNC/Generic notice may be related to either Part A or B services.
Once the BFCC-QIO is notified, they will contact the facility requesting more information about the case at which point the facility must respond to the request by submitting any documentation requested by the BFCC-QIO and issue a Detailed Explanation of Non-Coverage, or Detailed Notice, to the beneficiary or representative. The explanation must be completed within prescribed timeframes. Liability falls on either the facility or the beneficiary in the event of a missed deadline.
Here’s What They are Saying!
Both BFCC-QIO organizations recently announced that they will no longer facilitate receiving NOMNCs or communicate with facilities in response via telephone. Rather, they will only communicate via Fax. This is a huge change. Each organization has a banner on their home page making this announcement, see below.
LEVANTA: Attention Healthcare Providers: Livanta has changed how appeals notifications are received. Initial notification, medical record requests, and case outcomes are now by fax only. Click here to update your contact information.
- Already have an MOA with Livanta? To update your points of contact, click Update Points of Contact.
KEPRO: attention: updated notification process for new appeals – Starting on January 17, 2023, post-acute facilities and Medicare health plans will no longer receive phone calls for appeal notifications (when a new appeal has been filed). Post-acute facilities and Medicare health plans will receive fax notifications only. Acute care facilities and Medicare health plans will continue to receive both appeal notification phone calls and faxes for acute appeals. Read more on our appeals page.
- Keep your organization’s contact information up-to-date. This will help you receive timely communications without unnecessary delays. Visit www.keproqio.com/contact to update your information. If you don’t know who is listed as your organization’s point of contact, email MOA@kepro.com to verify.
There are two important steps that you facility should initiate immediately.
1. It is imperative that your facility contact your BFCC-QIO organization to ensure that the facility contact information, including the fax number on file, is up to date.
2. Initiate a process in your facility that will ensure that your team is aware of this change. Assign a team member to check for fax communication from the BFCC-QIO related to non-coverage situations and to communicate a timely response, especially on off-hours like weekends or holidays. Late or non-responses will result in financial liability for the facility.
If you have not done so already, please don’t delay to ensure that you facility adapts appropriately to this change.