Long-Term Care

Ask the expert: Medicare Part A

MDS 3.0 Insider, June 13, 2014

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Q:  When a Part A resident exhaust their Part A days and needs continued therapy under Part B, we have been writing the Part B POT and obtaining a signature by the MD. We have not billing for the Part B evaluation because it is a continuation of services. Is this correct?  Is there any CMS regulation to explain this pay or change?
A: My research does not produce any direct regulatory response, just inference.  In IOM 100-02 MBPM, Ch 15, §220, it implies that there needs to be a new evaluation under Part B regulation (even if it is a continuation of service) that meets the documentation requirements and is available for Medical Review.  It would include meeting all the other Part B documentation requirements including functional measurement and reporting, new cert, POC, etc.
After speaking with several therapists, three things seem to drive repeating the evaluation under the new payer source:
1.     Software:  Most software needs a new eval to switch payer sources
2.     Habit:  Prior to the implementation of the MACs, which handle both Part A and Part B claims, therapists usually completed a new evaluation since claims were paid by different contractors
3.     Medical reviewers looking for the new evaluation: During a Part B medical review, most reviewers are looking for the new eval.
You may want to confirm with your MAC, Provider Outreach Education Department, to determine what your MAC expects.

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