From the desk of our CEO Kris Mastrangelo:
Billing Noncovered Services for Skilled Nursing Facilities
Harmony frequently receives calls inquiring about completion of No-Pay Bills and Benefits Exhaust Claims. The SNF is REQUIRED to submit a bill for the Medicare beneficiary for every month of the SNF stay even when no Medicare benefits are payable. The SNF must submit a claim when the patient has exhausted the 100 SNF days. This claim is referred to as a Benefits Exhaust Bill. The SNF must submit a claim when the beneficiary no longer needs Skilled Care. This claim is referred to as a No-Pay Bill.
These billing requirements are in place because the Centers for Medicare and Medicaid Services (CMS) will maintain a record of all inpatient services for each Medicare beneficiary whether reimbursable or not.
The Medicare Contractor NHIC which covers Jurisdiction 14, recently conducted a Question and Answer session on this topic addressing many commonly asked questions. We have posted several of our favorites:
Question: The SNF patient had their benefits cut because they are no longer receiving a skilled level of care. The patient's family has requested that we file a demand bill to Medicare. What is the process that I need to follow?
Answer: Inpatient and outpatient providers are required to submit demand bills using condition code 20 when requested by the beneficiary. Billing with condition code 20 is ONLY in a case when an Advance Beneficiary Notice (ABN) is not given/not appropriate for billing related to doubtful liability. For ABN instruction see the CMS Internet Only Manual (IOM) Publication 100-04 Chapter 1 §60.4.1
Providers should break out demand billed services into separate claims with all noncovered charges whenever possible. Condition code 20 must be used. Occurrence code 32 (i.e., ABN) is NEVER submitted on a claim using condition code 20. All basic required claim elements must be completed. Reference the CMS IOM Publication 100-04 Chapter 1 §60.3.2
Question: The patient is receiving a non-skilled level of care in a certified bed within the SNF. What is my billing responsibility?
Answer: A no-pay claim is required for the patient that was previously receiving skilled care and has now dropped to a noncovered level of care and remains in a certified bed within the facility. The charges on a no-pay claim are submitted as noncovered. You may submit the no-pay claim as frequently as monthly when you need a denial notice for another insurer. Otherwise, you will submit the no-pay claim as frequently as necessary to meet the timely filing guidelines or upon patient discharge. No-pay claims may span several months in duration.
Question: How will the SNF patient's Medicare days ever be renewed if my patient is never discharged from the SNF?
Answer: The SNF patient's benefit period will be renewed when that patient has NOT received a skilled level of care for 60-consecutive days. Once the SNF patient's level of care is no longer skilled the SNF will report the occurrence code 22 - Date Active Care Ended on that claim in the next billing cycle. That occurrence code 22 will trigger the Common Working File (CWF) to begin counting that 60-consecutive day period.
Question: Am I required to bill a no-pay claim for my patient that did NOT require a skilled level of care at admission to the SNF?
Answer: Reference the CR 4292 guidelines. The no-pay claim is only required for those patients that were previously skilled upon admission to the SNF and subsequently dropped to a non-skilled level of care and remain in a certified bed within the facility.
Question: What is the difference between a benefits exhaust claim and a no-pay claim? I am not receiving reimbursement from the Medicare Program for either of these claim types.
Answer: The benefits exhaust claim is required for the patient that has exhausted their 100 Medicare SNF days and continues to receive a skilled level of care in a certified bed within the facility. The benefits exhaust claim is reported to Medicare as a "covered" claim.
The no-pay claim is required for those patients who are no longer receiving a skilled level of care but they continue to reside in a certified bed within the facility. The no-pay claim is reported to Medicare as a "noncovered" claim.
Question: Where will I locate the SNF Billing Guidelines?
Answer: Providers may reference the CMS IOM Publication 100-04 Chapter 6 for SNF Inpatient Part A Billing and SNF Consolidated Billing guidelines. Providers may reference the CMS IOM Publication 100-04 Chapter 7 for SNF Part B Billing guidelines.
To obtain a copy of the full session, click here:
http://www.medicarenhic.com/PA/billing/031611BillingNoncoveredServicesSNF.pdf
Spring Webinar Education Schedule
April 14, 2011
Pain Assessment & MDS 3.0
April 18, 2011
QIS Preparedness
90 Minute Webinar
April 19, 2011
MDS 3.0 for the CNA
May 19, 2011
Medicare Nursing/Therapy Documentation in a SNF
QIS PREPAREDNESS PROGRAM
8:30AM - 3:30PM
April 12, 2011 - Greer, SC
May 18, 2011 - West Islip, NY
