NOMNC (Notice of Medicare Non-Coverage)
The Notice of Medicare Non-Coverage (NOMNC, Form CMS-10123) is a standardized notice that tells a Medicare patient when all covered home health services will end and explains the right to a fast appeal through a Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO). Agencies must deliver it at least two calendar days before covered services end, and the requirement applies to both original Medicare and Medicare Advantage patients.
Timing and delivery rules
The NOMNC must be delivered no later than two calendar days before the last covered visit. When visits are spaced more than two days apart, deliver it by the second-to-last visit. The patient or an authorized representative must sign and date the notice to acknowledge receipt; when the representative is not physically present, agencies may deliver the notice by phone, document the conversation, and mail a copy the same day. A notice signed at the final visit is late, and late or missing NOMNCs are among the most commonly cited beneficiary notice failures in home health.
How the fast appeal works
A patient who disagrees with the end of coverage contacts the BFCC-QIO listed on the notice, generally by noon of the day before services are scheduled to end. The agency must then promptly give the QIO the medical records it needs and provide the patient a Detailed Explanation of Non-Coverage (DENC, Form CMS-10124) explaining specifically why coverage is ending. The QIO issues an expedited decision. If it sides with the agency, the patient becomes financially responsible for care received after the planned end date; if it sides with the patient, covered services continue.
Who must receive a NOMNC
The NOMNC is required whenever all Medicare-covered home health services are ending for coverage reasons, and it applies to Medicare Advantage members as well as original Medicare patients, a point agencies with heavy MA census sometimes miss. It is not used for reductions in some services while others continue; that is HHCCN territory. Advance delivery also is not expected when the ending is genuinely unplanned, for example the patient is hospitalized, dies, or refuses further care, though the circumstances should be clearly documented in the record.
Common pitfalls
Watch for these recurring failures:
- Delivering the NOMNC at the last visit instead of two days ahead
- Missing signatures or missing dates, which invalidate the notice
- Forgetting Medicare Advantage patients need the notice too
- Planning discharges around weekends without accounting for appeal timelines
- Field staff unable to explain the notice, turning a rights document into a signature ritual
Building NOMNC delivery into the discharge planning workflow, triggered when the discharge date is set, prevents most of these.
Frequently asked questions
Does the NOMNC apply to Medicare Advantage patients?
Yes. Medicare Advantage members are entitled to the same notice and expedited appeal process when all covered home health services end, and MA plans expect contracted agencies to deliver it on time.
What happens if the patient files a fast appeal?
The agency promptly sends the QIO the relevant records and gives the patient a Detailed Explanation of Non-Coverage (DENC). The QIO issues an expedited decision, and the patient generally is not liable for continued care before the decision when the appeal was filed on time.
Do we issue a NOMNC if the patient is hospitalized or refuses care?
Advance notice is not expected when services end unexpectedly, such as a hospitalization, death, or the patient's own decision to stop care. Document the circumstances thoroughly, since surveyors and plans will look for the reason no NOMNC was delivered.