When billing for skilled nursing facility (SNF) patients who present to your oncology practice for chemotherapy and associated services, you may be tempted to thank your lucky stars for the many oncology services that are excluded from consolidated billing but don't get smug yet. The Balanced Budget Act of 1997 requires SNFs to consolidate their billing for Medicare Part Aresidents, thus turning reimbursement into even more of a monster when it comes to nursing-home patients. If your oncologist is billing every single service for SNF patients directly to Medicare, don't expect more than consistent problems. Patients Suffer Most in the Long Run According to Elaine Towle, CMPE, practice administrator for New Hampshire Oncology and Hematology in Hooksett, coordinating care for SNF patients not only creates a billing morass but also raises access-to-care issues. When patients are transferred from a hospital to an SNF, the SNF may be reluctant to accept those patients because the costly chemotherapy burden will fall on the nursing home's shoulders. While an SNF can't refuse a patient solely on account of cost, they have been known to use low staffing to justify turning patients away, says Rusti Bauman, RN, BSN, MS, a nurse consultant with FR&R Healthcare Consulting in Deerfield, Ill. Whether or not the SNF's tale of woe is true, all that oncology coders and billers can do is bite the bullet and "dive into that HCPCS code list and figure out on a case-by-case basis what you can bill," Bauman says. Chemo and J Codes Excepted From SNF Billing The list of codes that are excluded from consolidated-billing requirements includes the common chemotherapy administration codes (the 96400 series) and a fat selection of J codes. When you treat SNF patients, these procedures will get submitted to your Medicare carrier as normal, and you can expect your typical reimbursement, Towle says. Medicare will also pay for office visits when appropriate. Lab, Ancillary Services Are a Part of Consolidated Billing Unfortunately, the list of services that fall under consolidated-billing requirements and thus must be submitted directly to the nursing home is equally daunting. Clinical Example But don't think you can take refuge in easy generalizations, Bauman cautions. Even closely related codes can fall on different sides of the great consolidated-billing divide. The only difference lies in the last two lines of the description, which detail whether the technologist screens or the physician interprets the test. "You can't even tell your coders to bill a simple screening cytopathology the same way every time," Bauman laments. To take another example, CMS tells physicians to bill G0104 (Colorectal cancer screening; flexible sigmoi-doscopy) to the carrier. However, if the alternative test is performed with a barium enema, G0106 (Colorectal cancer screening; alternative to G0104, screening sigmoi-doscopy, barium enema), SNFs must bill this service. Forge Relationship With SNF The dilemma is, from a practical standpoint, how to identify these patients so you can appropriately bill the SNF for category-X services and Medicare for the rest of the services. Make arrangements with the nursing home for the billing, and go ahead and bill the carrier for their services and bill the SNF for their services. Don't wait until an SNF patient presents for her appointment before you think about how to code the service. When the SNF calls to schedule the procedure, the receptionist should note the patient's fee ticket to ensure that the coder knows the patient resides in an SNF. In order to streamline payment, "when the fee ticket gets to the coder, he or she should create another, separate fee ticket," says Deb Hudson, CCS-P, coder at the Mason City Clinic, a 35-physician multispecialty practice in Iowa. Consolidated Wisdom The bottom line, Towle and Bauman say, is that there's little that's easy or good about consolidated billing for oncology practices. "They are carrying a burden of tremendous coordination and little reimbursement," Bauman says.
Towle says that the list includes most laboratory services as well as any other ancillary services provided at the time of chemotherapy, the administration of antiemetics, growth factors and premedications such as hydration therapy, and non-chemotherapy infusions (90780-90781). None of these can be billed directly to Medicare; instead, they must be billed to the nursing home, which then reimburses the oncology practice.
For example, suppose an SNF patient in a covered Part Awith a history of cervical cancer presents to a gynecological oncologist for a screening cytopathology. When the coder submits the claim to the patient's Medicare carrier, she needs to know who reviewed the test because that detail will determine how the test may be billed.
G0123 (Screening cytopathology, cervical or vaginal [any reporting systems], collected in preservative fluid, automated thin layer preparation, screening by cytotech-nologist under physician supervision) is not excluded, and the SNF must bill this service, while G0124 (Screening cytopathology, cervical or vaginal [any reporting systems], collected in preservative fluid, automated thin layer preparation, requiring interpretation by physician) is excluded, and the physician can bill directly to the carrier.
"You can go crazy trying to figure out what to bill where," Bauman says. "You have to familiarize yourself with this huge file and cross-reference it with the procedures and tests that your practices actually performs."
For the complete list of the more than 11,000 procedures covered by consolidated billing, go to the CMS Web site http://cms.hhs.gov/manuals/pm_trans/A0194.pdf.
Hudson suggests setting up separate accounts for the various SNFs in your area so the information is sent to the appropriate party at the nursing facility for reimbursement.
She says that this process has worked well for her practice, and she reminds coders to include the SNF "OSCAR" number (which identifies the facility) on all claims for SNF patients.