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SNF Medicare Billing Changes Effective August 1, 2011

Two significant updates to Medicare Part A claims for skilled nursing facilities (SNFs) and hospital swing-bed providers will occur with dates of service beginning August 1, 2011. The Centers for Medicare & Medicaid Services (CMS) is making the following changes through Change Request 7339:

  • Any Part A claim reporting an End of Therapy Other Medicare Required Assessment (OMRA) must include Occurrence Code 16 and the date of the last therapy service.
  • Therapy units reported with revenue codes 0420, 0430 or 0440 on Part A claims are changed to represent the number of calendar days of therapy provided by discipline, regardless of the number of minutes or types of therapy services provided. According to the CMS Division of Institutional Claims Processing, therapy evaluations will continue to be reported separately under revenue codes 0424, 0434 and 0444.
    For example, if a resident was covered by Medicare Part A from August 1 to August 4, 2011, and received physical therapy and occupational therapy services each day during that period, the August claim would include four units of physical therapy and four units of occupational therapy. The number of minutes and types of therapy services for Part A-covered residents is irrelevant for determining the number of units on the claim.

To prepare for these changes, providers should discuss these issues with their software vendor and therapy services provider to determine how information will flow into billing software programs and to Medicare Part A claims.

If you have any questions about this or other SNF Medicare billing issues, contact your BKD advisor.

This post was written by:

Jennifer serves as industry manager of the long-term care and senior living operations for BKD health care billing services. She provides training and compliance guidance related to Medicare, Medicare managed care, Medicaid and commercial insurance billing for long-term facilities.

10 Responses to “SNF Medicare Billing Changes Effective August 1, 2011”

  1. avatar Sue Burgin says:

    Jennifer – What am I suppose to do if the patient is admitted toward the end of the month and the assessment reference date is into the next month. How many days of therapy do I show. Do I use the number of days left in that calendar month, or do I use the number of therapy days needed to justify the RUG level. I have been concerned about this because I don’t want the claim to be denied because I have done something wrong. Thanks for any help you can give me. Sue

  2. avatar Jennifer Wormington says:

    This can be a confusing issue. The number of units of therapy to be billed on a Medicare Part A claim is not impacted by the ARD date or the admission date. The claim should include the actual number of days that therapy was provided to the beneficiary during the claim dates of service (from and through dates on the claim). There may be times when you have a Rehabilitation RUG category that is being billed without therapy units on the claim. This can occur if the resident is admitted very late in the month and therapy does not start until the next month but the resident still qualifies for a Rehabilitation RUG category with the established ARD date. In this situation, you would submit a claim without therapy units and may have to utilize Medicare’s therapy “work around” in order for claims to be processed for payment.

  3. avatar Sharon says:

    Are these changes required on a claim submitted as a Medicare Secondary Payer (MSP) claim?

  4. avatar Jennifer Wormington says:

    The changes are required on any claim submitted to Medicare for Part A covered services including claims to Medicare as a secondary payer (MSP) with a 21x bill type. If you are submitting a Part B services claim, or an MSP claim for ancillary only services on a 22x or 23x bill type, then the change in therapy unit reporting does not apply.

  5. avatar Angela says:

    Do you have an example of a UB04 with the new updates. If a patient is seen by pt, ot and ST I know it represents as 1 day and billed as one unit but what code would I reflect on the UB04? 0420, 0430 or 0440?

  6. avatar Jennifer A. Wormington says:

    Each therapy discipline is counted individually. If someone receives PT, OT & ST on one day then you would have 1 unit of PT, 1 unit of OT and 1 unit of ST (total of 3 units) on the claim. You would continue to use the revenue codes that you have always used for reporting the number of units and charges for each therapy discipline.

  7. avatar Jeff says:

    I assume that each discipline (PT, OT, ST) must still treat the patient separately in order to bill a unit. In other words, how does it work if PT and OT co-treat a patient?

  8. avatar Julie Bilyeu says:

    Each therapy discipline is reported separately by revenue code. For example; if a patient had 5 calendar days of PT and 5 calendar days of OT you would report 5 units for each discipline to the appropriate revenue codes on the claim form.

  9. avatar ar says:

    can ot and pt bill for treatment when they provide the “so-called ” treatment during the evaluation process? For example touching a patient in and off itself does not justify billing for skilled are during the evaluation. Thanks

  10. avatar Julie Bilyeu says:

    We agree that simply touching the patient is not skilled therapy. The evaluation must be completed so that the plan of care can be developed and further treatments can be provided. Therapy treatment can be provided the same day as the evaluation as long as the evaluation has been completed first. We recommend the evaluation time and the treatment time be documented on the therapy log to prevent confusion on capturing and coding as well as billing.

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Recent Comment

  • Karen Vance says:
    This would be under §484.18 of the Conditions of Participation describing regulations for the Plan of Care. Below is the Standard that addresses your issue: "§484.18(b) - Agency professional staff promptly alert the physician to any changes that suggest a need to alter the plan of care." From the State Operations Manual (guidance for state surveyors) "The
    February 24, 2011 on Webinars

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