How to Appeal a SNF Discharge in Illinois

Your parent has been in a skilled nursing facility for three weeks of rehab. They're making progress—slowly—but the facility just handed you a Notice of Medicare Non-Coverage saying benefits end in two days. They're not ready to go home.

You can fight this. Here's how to appeal a SNF discharge in Illinois.

Understanding the Notice of Medicare Non-Coverage (NOMNC)

When a SNF determines that a patient no longer requires daily skilled care (or is approaching the 100-day Medicare limit), the facility must deliver a written Notice of Medicare Non-Coverage (NOMNC) at least two calendar days before covered services end.

The NOMNC must state:

• The date Medicare coverage will end
• The reason coverage is being terminated
• Your right to request an expedited review

This notice is not the same as being told to leave the facility. It means Medicare stops paying—but you can appeal, and while the appeal is pending, coverage continues.

Filing an Expedited Appeal

The process mirrors the hospital discharge appeal:

Step 1: Contact Acentra Health (Illinois's BFCC-QIO) no later than noon on the day before covered services are scheduled to end.

• Toll-free: 888-317-0751 (9 AM–5 PM weekdays, 10 AM–4 PM weekends/holidays)
• Fax: 844-878-7921

Step 2: Tell them you're filing an expedited appeal of a Medicare non-coverage determination for SNF services.

Step 3: Acentra requests clinical records from the facility. They review whether your parent still meets skilled care criteria.

Step 4: Decision within 24-48 hours:

• Overturned: Medicare coverage continues. Your parent stays with full benefits.
• Upheld: Coverage ends on the date specified. You can request a second-level review.

Critical protection: While the expedited appeal is pending, the facility cannot charge your parent for the days under review. Medicare continues to pay until a decision is reached.

What Counts as Continued Skilled Need

Medicare covers SNF care when the patient needs daily skilled nursing or therapy that can only be provided in this setting. Your appeal is stronger if you can document:

• Active therapy goals not yet met (increasing distance walked, regaining ability to dress independently)
• Skilled nursing needs (wound care, IV medications, complex medication management)
• Functional improvement that's ongoing—even if slow
• Safety risks that prevent discharge (fall risk without supervision, inability to manage medications independently)
• Caregiver at home is unable to provide the level of care needed

Medicare does not require that the patient be improving—only that skilled services are reasonable and necessary. A patient maintaining function who would decline without skilled intervention can still qualify.

When a Nursing Home Tries to Evict a Medicaid-Pending Resident

A separate but related crisis: your parent's Medicare days ran out, you applied for Medicaid, and the nursing home wants them out because Medicaid hasn't approved yet.

Under the Illinois Nursing Home Care Act, a facility cannot involuntarily discharge a resident without:

• 30 days written notice
• A valid discharge reason (nonpayment is one, but Medicaid-pending has specific protections)
• Notifying the Illinois Long Term Care Ombudsman
• Giving the resident the right to appeal through IDPH

If the Medicaid application is genuinely pending and the resident was admitted under the expectation of Medicaid coverage:

• The facility accepted the risk of the application timeline
• Medicaid reimburses retroactively once approved—the facility will be paid
• Eviction during a pending application is often improper, especially if the facility accepted Medicaid patients and knew the timeline

File a complaint with the Long Term Care Ombudsman at 800-252-8966 if a facility threatens discharge during Medicaid pending status.

Resident Rights Under the Illinois Nursing Home Care Act

Beyond the Medicare appeal, Illinois residents have statutory rights:

• Right to remain in the facility absent valid discharge criteria
• Right to 30-day advance written notice before any involuntary discharge
• Right to appeal involuntary discharge to the Illinois Department of Public Health
• Right to readmission if the discharge is found improper
• Right to access personal funds on deposit with the facility
• Right to refuse transfer to another room or unit without clinical justification

After the Appeal: Planning Next Steps

Whether the appeal succeeds or fails, you need a plan:

If appeal succeeds: Coverage continues, but the facility will likely issue another NOMNC when clinical criteria are next reviewed. Use the extension to maximize therapy and prepare for eventual discharge home.

If appeal fails: Options include:

• Private pay at the SNF rate ($7,500-$9,500/month in Illinois)
• Transition to Medicaid coverage if financially eligible (no three-day requirement)
• Discharge home with Community Care Program or home health services
• Transfer to a Supportive Living Facility (lower-cost assisted living alternative)

The Hospital-to-Home Illinois toolkit covers the full transition pathway from SNF back to home, including how to request a CCU assessment for Community Care Program services and what documentation strengthens your coverage appeal.

See more Illinois guides →