O&P Practitioners Providing Services in Skilled Nursing Facilities (SNF's)
NAAOP
Description
Collection
Title:
O&P Practitioners Providing Services in Skilled Nursing Facilities (SNF's)
Creator:
NAAOP
Date:
1/28/2000
Text:
To O&P Practitioners Providing Services in Skilled Nursing Facilities
(SNF's)
The Balanced Budget Refinement Act of 1999 (BBRA '99), enacted this past
December, contains a number of significant changes that impact O&P providers
practicing in SNFs. All of the changes are positive, both for patients and
for O&P practitioners.
As part of the Balanced Budget Act of 1997 (BBA '97), Congress enacted a
prospective payment system (PPS) for residents of Skilled Nursing
Facilities. The SNF PPS went into effect over the past two years and
resulted in a drastic decrease in access to prosthetic services for
residents in the first 100 days of a SNF stay (what is known as the Part A
stay). This occurred because the SNF was required to pay the provider
directly for the prosthetic services performed out of the SNF's per diem
rate they receive for all patients. Services and devices such as
prostheses, ambulance rides for dialysis treatments, chemotherapy drugs,
etc., are unique to the individual and not inexpensive. Congress and HCFA
found that SNF residents were restricted in their access to these services
under the SNF PPS.
The BBRA '99 exempted the bulk of Prosthetic L-codes from the SNF PPS. (A
list of these codes can be obtained by contacting NAAOP by e-mail at
<Email Address Redacted> ). This exemption takes effect on April 1, 2000 for
prosthetic services performed on or after that date. Once the new law takes
effect, O&P practitioners will once again be able to bill Medicare directly
for the services they perform in SNFs. Until that date, the O&P provider
has limited options to be reimbursed for such services. The provider must
continue to bill the SNF for any services performed on residents until April
1st, assuming the resident is covered under the Part A stay. If 100 days
have elapsed, the resident becomes covered for prosthetics under Part B of
the program and the practitioner may bill Medicare directly for services
provided to the resident. Of course, if a SNF resident is discharged to his
or her home, Medicare can be billed directly as well.
The National Association for the Advancement of Orthotics and Prosthetics
(NAAOP) is very pleased to announce that HCFA has interpreted the BBRA '99
exclusion of prosthetics to also apply to the Consolidated Billing
provisions contained in the BBA '97. NAAOP and other O&P organizations had
been advocating this position for some time. Currently, consolidated
billing has been indefinitely postponed, but it is expected to be
implemented within the next year. Under the consolidated billing provisions
of the BBA '97, O&P practitioners would have been required to bill all O&P
services provided to SNF residents (not within their initial 100 day stay)
to the Skilled Nursing Facility, not to Medicare directly. Each SNF would
consolidate the bills for services performed on all residents and then
submit a master bill to Medicare. Medicare would pay the SNF and the SNF
would pay the O&P provider a negotiated fee for the services performed. With
this recent news from HCFA, this potential nightmare will not occur. All of
the prosthetic L-codes that are exempt from the SNF PPS will also be exempt
from consolidated billing, once the consolidated billing provisions go into
effect.
Finally, the missing link in this scenario is orthotics. Perhaps due to the
increased amount of fraud and abuse that is perceived to exist in the
provision of orthoses in nursing homes, HCFA and Congress have not treated
orthotics in the same manner in which they are treating prosthetics. NAAOP
will continue to advocate for an exemption from the SNF PPS and the
consolidated billing provisions for orthotics, particularly orthoses that
require a significant degree of customization and result in significant
reimbursement. It is NAAOP's position that only an exemption from these
payment systems will ensure that SNF residents have access to comprehensive
orthotic care.
Prepared by Peter W. Thomas
General Counsel
National Association for the Advancement of Orthotics and Prosthetics
(NAAOP)
e-mail: <Email Address Redacted>
fax: (202) 737-2517
(SNF's)
The Balanced Budget Refinement Act of 1999 (BBRA '99), enacted this past
December, contains a number of significant changes that impact O&P providers
practicing in SNFs. All of the changes are positive, both for patients and
for O&P practitioners.
As part of the Balanced Budget Act of 1997 (BBA '97), Congress enacted a
prospective payment system (PPS) for residents of Skilled Nursing
Facilities. The SNF PPS went into effect over the past two years and
resulted in a drastic decrease in access to prosthetic services for
residents in the first 100 days of a SNF stay (what is known as the Part A
stay). This occurred because the SNF was required to pay the provider
directly for the prosthetic services performed out of the SNF's per diem
rate they receive for all patients. Services and devices such as
prostheses, ambulance rides for dialysis treatments, chemotherapy drugs,
etc., are unique to the individual and not inexpensive. Congress and HCFA
found that SNF residents were restricted in their access to these services
under the SNF PPS.
The BBRA '99 exempted the bulk of Prosthetic L-codes from the SNF PPS. (A
list of these codes can be obtained by contacting NAAOP by e-mail at
<Email Address Redacted> ). This exemption takes effect on April 1, 2000 for
prosthetic services performed on or after that date. Once the new law takes
effect, O&P practitioners will once again be able to bill Medicare directly
for the services they perform in SNFs. Until that date, the O&P provider
has limited options to be reimbursed for such services. The provider must
continue to bill the SNF for any services performed on residents until April
1st, assuming the resident is covered under the Part A stay. If 100 days
have elapsed, the resident becomes covered for prosthetics under Part B of
the program and the practitioner may bill Medicare directly for services
provided to the resident. Of course, if a SNF resident is discharged to his
or her home, Medicare can be billed directly as well.
The National Association for the Advancement of Orthotics and Prosthetics
(NAAOP) is very pleased to announce that HCFA has interpreted the BBRA '99
exclusion of prosthetics to also apply to the Consolidated Billing
provisions contained in the BBA '97. NAAOP and other O&P organizations had
been advocating this position for some time. Currently, consolidated
billing has been indefinitely postponed, but it is expected to be
implemented within the next year. Under the consolidated billing provisions
of the BBA '97, O&P practitioners would have been required to bill all O&P
services provided to SNF residents (not within their initial 100 day stay)
to the Skilled Nursing Facility, not to Medicare directly. Each SNF would
consolidate the bills for services performed on all residents and then
submit a master bill to Medicare. Medicare would pay the SNF and the SNF
would pay the O&P provider a negotiated fee for the services performed. With
this recent news from HCFA, this potential nightmare will not occur. All of
the prosthetic L-codes that are exempt from the SNF PPS will also be exempt
from consolidated billing, once the consolidated billing provisions go into
effect.
Finally, the missing link in this scenario is orthotics. Perhaps due to the
increased amount of fraud and abuse that is perceived to exist in the
provision of orthoses in nursing homes, HCFA and Congress have not treated
orthotics in the same manner in which they are treating prosthetics. NAAOP
will continue to advocate for an exemption from the SNF PPS and the
consolidated billing provisions for orthotics, particularly orthoses that
require a significant degree of customization and result in significant
reimbursement. It is NAAOP's position that only an exemption from these
payment systems will ensure that SNF residents have access to comprehensive
orthotic care.
Prepared by Peter W. Thomas
General Counsel
National Association for the Advancement of Orthotics and Prosthetics
(NAAOP)
e-mail: <Email Address Redacted>
fax: (202) 737-2517
Citation
NAAOP, “O&P Practitioners Providing Services in Skilled Nursing Facilities (SNF's),” Digital Resource Foundation for Orthotics and Prosthetics, accessed November 5, 2024, https://library.drfop.org/items/show/213468.
