Fails: coverage ends or care becomes non-skilled but no NOMNC/SNFABN was issued or the delivery was not documented — liability cannot shift and appeal rights were not honored.
Survives: the NOMNC delivered at least two calendar days before the last covered day with signature and BFCC-QIO appeal information, or the SNFABN issued before non-covered Part A care — delivery documented in the record.
The common fix
Every pattern above resolves the same way: state the actual finding and its objective reference (never “at baseline”); name the licensed-level reason a clinician was required; prove the need was daily and could be met only in a SNF; quantify the effect (or the skill required to maintain); support the MDS; and close the loop with the required notifications. Applied consistently, these are the disciplines Foundations teaches and the Compliance checklist enforces.
