Medicare Compliance & Reimbursement

SNFs can keep their claims humming by noting these CB shifts.

Clarifying is the name of the game, it seems, at the Centers for Medicare & Medicaid Services -- at least as far as long-term care billing is concerned. At its SNF/Long-Term Care Open Door Forum held June 29, CMS officials issued a number of need-to-know clarifications for SNFs.

Though some of the concerns are likely to affect relatively few providers, the matters are enough to warrant a midyear consolidated billing update, said CMS' Sheila Lambowitz, who noted the clarifications at the forum.

Look for the update at www.cms.hhs.gov/medlearn/refsnf.asp by the middle of this month.

In the meantime, here's how the changes could affect long-term care providers:

Chemotherapy. Lambowitz reminded providers that three separate bills are generated when it comes to chemotherapy services for SNF residents: Medicare contractors field the one for professional services and the bill for the chemotherapy agent itself, but a third bill goes to the SNF for supplies not excluded from consolidated billing.

Those who listened to May's Open Door Forum may have held out hope that they could bill separately for epo (short for erythropoietin). Not so in most cases, reported Lambowitz. Though an old manual on CMS' Web site suggested otherwise, epo is billable only when services are provided at an end stage renal disease facility or through a home dialysis program. CMS has taken steps to nip confusion in the bud by labeling old online documents as "historical" documents.

Navigate online CMS manuals carefully, checking issue date and any forthcoming CMS warnings that some volumes are obsolete.

Ambulance transfers to doctor visits. "Our policy has not changed regarding which ambulance services are separately billable," offered Lambowitz, taking a step back from a recently issued Change Request and related Medlearn Matters article that, in seeking to clarify policy regarding ambulance transfers, actually muddied the water in a new way. Some interpreted the Medlearn article as suggesting that Medicare would pay separately for a patient to go by ambulance to an off-site physician visit. It won't, clarifies Lambowitz. The wording in the Change Request could have been clearer, she allowed.

Codes 97110 and 97112. The final consolidated billing question of the forum dealt with two therapy-related codes, 97110 (Therapeutic exercises) and 97112 (Neuromuscular reeducation). Could speech pathologists bill for services using the codes in a SNF (or any other setting)? Lambowitz suggested that while no practitioner type is excluded from using the general codes, guidelines do call for practitioners to use the code that best describes services rendered. That means another more specific code is probably advisable, such as 92507 (Treatment of voice, language, speech, communication or auditory processing). Want further clarification? Contact CMS'Pam West at pwest@cms.hhs.gov.

Other forum news:

What's hospice? CMS' Mary Pratt directed long-term care providers to the agency's new update regarding what meets the Minimum Data Set criteria for hospice care.

The agency's verdict is that only Medicare certification or state hospice licensure qualifies a program as hospice for MDS purposes.

The clarification concerning hospice care and the MDS should be posted soon at www.cms.hhs.gov/quality/mds20/rai0604upd.pdf.

Notices of coverage/noncoverage. CMS reported that the agency is further revising the recently released SNF ABN. It is also devising a new form that will be used to notify SNF residents of Medicare noncoverage ("Notice of Exclusion" form). Both new forms will be posted by late July for an informal 30-day comment period, CMS reported. Providers have about seven months before the new forms will be approved and ready for implementation, notes consultant Steven Jones, a shareholder with Moore Stephens Lovelace in Clearwater, FL.

Alcohol-based hand rubs. Providers should hold off on mounting dispensers of alcohol-based hand sanitizer in the corridors and public areas of skilled nursing facilities. Why? Though the National Fire Protection Agency earlier this year amended the Life Safety Code 2000 edition to allow such placement of the dispensers (prompted in part by efforts by the Centers for Disease Control and Prevention to increase the use of hand sanitizers by health care personnel) surveyors are being advised to cite facilities for related violations until CMS formally adopts the hand rub dispenser amendment through a formal rulemaking process.

Address any related questions you may have to jsim-mons1@cms.hhs.gov.