New rules on default billing end CMS flip-flops
Billing Alert for Long-Term Care, October 1, 2008
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With the August publication of the skilled nursing facility (SNF) PPS and consolidated billing final rule for fiscal year 2009, CMS finally put to rest more than a year of confusion regarding exactly when SNFs can bill the Medicare Part A default rate if a PPS MDS assessment hasn’t been completed and accepted into the state database, says Rena R. Shephard, MHA, RN, RAC-MT, C-NE, founding chair and executive editor of the American Association of Nurse Assessment Coordinators and president of RRS Healthcare Consulting Services in San Diego.
In March 2007, CMS published Transmittal 196 to update SNF PPS medical review policies. The transmittal’s stringent limitations on billing the default rate when an MDS wasn’t completed set off an uproar in the nur-sing home industry and created conflicting opinions among CMS officials. At SNF/Long-Term Care Open Door Forums throughout 2007 and early this year, agency officials made several reversals in their thinking about default billing.
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