SNF billing policy
Description
Collection
Title:
SNF billing policy
Text:
Thank you to those who responded!!
My orignial post:
In a nutshell, my understanding of Billing SNFs is that the first 100
days, we must bill the SNF, except prosthetics. If you fully understand the
current policy and have an inside line on how it may change please send me a
message, as our SNFs are giving us conflicting info. I will post responses. I
am trying to locate my last update from AOPA and they are snowed in!!
Thanks,
Randy McFarland,CPO
The responses:
Randy:
Here is an update on the SNF billing situation. As long as the patient is
covered by Part A in the SNF (up to the first 100 days), in general you must
bill the SNF. They are paid for your services in the PPS RUG rate (the per
diem/per patient payment) they receive from Part A. After the patient uses
up his/her Part A coverage, or if they do not have Part A, you can provide
the service in the SNF and bill the DMERC directly.
The only exception to this is that if you provide a device to a Part A
patient, for fitting or training purposes, within 2 days of the date of
discharge from the SNF, you can bill the DMERC directly, using the date of
discharge as the date of service. Some serious concerns here...you must be
comfortably saying that the reason you provided it at that time was for
fitting/training purposes. If you can not, you cannot bill the DMERC.
Also, HCFA is in the process of revising the rules here, so if you decide to
make use of this rule, keep the bulletin you received from your DMERC on
this topic (they came out with this ruling in Dec. of 98), in case someone
asks why you are billing directly for services in a SNF. Also, while it is
unlikely, if HCFA decides to rescind this rule, it is not outside the realm
of possibility that they could ask for a refund, which you would have to
fight.
Also, if the DMERC sees that all of the sudden all of your SNF patients
are
receiving their services during this window, they may decide to take a look
at why. As you may have guessed by now, I'm not real comfortable with this
ruling, but within certain parameters, it is legitimate, at least for now.
The O&P changes from the recent legislation amending the Balanced Budget
Act
do not take affect until April 1. At that time most prosthetic services
(see the AIA of Dec. 7 for a complete list of codes) will be excluded from
SNF PPS. However, what has not been determined yet is who will bill for
these services. HCFA may say that the SNF must still bill, or they may say
that you can bill the DMERC directly. We have been pushing for the latter,
but the final decision has not yet been made. We are also working with
Congress and HCFA to get orthotics excluded as well.
Hope this info. helps. If you need anything else, give me a call.
Kathy Dodson
Director of Reimbursement Services
703 836-7116
<Email Address Redacted>
Your nutshell description is correct once HCFA writes the regulations that
will implement the Prosthetics exemption that was included in the Budget
Conference Agreement. The legislative implementation date for this
exemption is April 1, 2000. Realistically, HCFA will not have the regs in
place in time for this date. We probably won't see the exemption for
prosthetics go into effect until the summer of 2000. There are several
regulatory hoops that HCFA must jump through in order to implement the
exemption. Until these regs are in place, you still need to get purchase
orders during the 100 days of Medicare Part A SNF benefits. You can find
back copies of the AOPA In Advance on their website www.aopanet.org It is
in the members only section. You will need a password that you should have
assuming you are an AOPA member. If you have any other questions, call me
at (301) 280-4528 and I will help however I can.
Joe McTernan
Director of Regulatory Affairs
Hanger Prosthetics & Orthotics.
I have been told by one ECU unit of Hospital that O&P are excluded? Still
can't get clear answer. Have you tried in4medic.com? I think that is the
site.
For O&P care in a SNF, Medicare part A must be exhusted,or the patient cannot
have part A,( then part b can cover services).
If they are in the SNF under part A, the SNF must pay for services for the
1st 100 days.
After patient uses up their 100 days, part B can be billed.
After 60 days of discharge or part B benefits, the patient can come back to
the SNF under part A again.
Part B can be billed on the day of discharge from the SNF, (or the last day
of the 100 day stay)
Certain prosthetic codes are not expempt from this until 4-1-2000
Hope this helps
Braceon, CPO
My orignial post:
In a nutshell, my understanding of Billing SNFs is that the first 100
days, we must bill the SNF, except prosthetics. If you fully understand the
current policy and have an inside line on how it may change please send me a
message, as our SNFs are giving us conflicting info. I will post responses. I
am trying to locate my last update from AOPA and they are snowed in!!
Thanks,
Randy McFarland,CPO
The responses:
Randy:
Here is an update on the SNF billing situation. As long as the patient is
covered by Part A in the SNF (up to the first 100 days), in general you must
bill the SNF. They are paid for your services in the PPS RUG rate (the per
diem/per patient payment) they receive from Part A. After the patient uses
up his/her Part A coverage, or if they do not have Part A, you can provide
the service in the SNF and bill the DMERC directly.
The only exception to this is that if you provide a device to a Part A
patient, for fitting or training purposes, within 2 days of the date of
discharge from the SNF, you can bill the DMERC directly, using the date of
discharge as the date of service. Some serious concerns here...you must be
comfortably saying that the reason you provided it at that time was for
fitting/training purposes. If you can not, you cannot bill the DMERC.
Also, HCFA is in the process of revising the rules here, so if you decide to
make use of this rule, keep the bulletin you received from your DMERC on
this topic (they came out with this ruling in Dec. of 98), in case someone
asks why you are billing directly for services in a SNF. Also, while it is
unlikely, if HCFA decides to rescind this rule, it is not outside the realm
of possibility that they could ask for a refund, which you would have to
fight.
Also, if the DMERC sees that all of the sudden all of your SNF patients
are
receiving their services during this window, they may decide to take a look
at why. As you may have guessed by now, I'm not real comfortable with this
ruling, but within certain parameters, it is legitimate, at least for now.
The O&P changes from the recent legislation amending the Balanced Budget
Act
do not take affect until April 1. At that time most prosthetic services
(see the AIA of Dec. 7 for a complete list of codes) will be excluded from
SNF PPS. However, what has not been determined yet is who will bill for
these services. HCFA may say that the SNF must still bill, or they may say
that you can bill the DMERC directly. We have been pushing for the latter,
but the final decision has not yet been made. We are also working with
Congress and HCFA to get orthotics excluded as well.
Hope this info. helps. If you need anything else, give me a call.
Kathy Dodson
Director of Reimbursement Services
703 836-7116
<Email Address Redacted>
Your nutshell description is correct once HCFA writes the regulations that
will implement the Prosthetics exemption that was included in the Budget
Conference Agreement. The legislative implementation date for this
exemption is April 1, 2000. Realistically, HCFA will not have the regs in
place in time for this date. We probably won't see the exemption for
prosthetics go into effect until the summer of 2000. There are several
regulatory hoops that HCFA must jump through in order to implement the
exemption. Until these regs are in place, you still need to get purchase
orders during the 100 days of Medicare Part A SNF benefits. You can find
back copies of the AOPA In Advance on their website www.aopanet.org It is
in the members only section. You will need a password that you should have
assuming you are an AOPA member. If you have any other questions, call me
at (301) 280-4528 and I will help however I can.
Joe McTernan
Director of Regulatory Affairs
Hanger Prosthetics & Orthotics.
I have been told by one ECU unit of Hospital that O&P are excluded? Still
can't get clear answer. Have you tried in4medic.com? I think that is the
site.
For O&P care in a SNF, Medicare part A must be exhusted,or the patient cannot
have part A,( then part b can cover services).
If they are in the SNF under part A, the SNF must pay for services for the
1st 100 days.
After patient uses up their 100 days, part B can be billed.
After 60 days of discharge or part B benefits, the patient can come back to
the SNF under part A again.
Part B can be billed on the day of discharge from the SNF, (or the last day
of the 100 day stay)
Certain prosthetic codes are not expempt from this until 4-1-2000
Hope this helps
Braceon, CPO
Citation
“SNF billing policy,” Digital Resource Foundation for Orthotics and Prosthetics, accessed November 5, 2024, https://library.drfop.org/items/show/213549.
