Corporate Compliance

Tip: Ensure discharge dispositions don't affect reimbursement

Compliance Monitor, May 9, 2012

Incorrect discharge disposition can result in CMS recoupments from referring acute facilities, postacute facilities, and physicians. Each facility must decide how it will validate the post acute transfer (PACT) policy. The intent of PACT is to protect CMS from overpayments or paying for the same care twice—to the hospital and the postacute provider.

Hospitals receive front-loaded payments of twice the per diem rate on the first day of a stay and a per diem up to a full MS-DRG payment.  CMS views stays shorter than the geometric mean LOS for an assigned MS-DRG as less than the full course of treatment, and it has concluded that transferring hospitals should not receive full MS-DRG payments. [GS1] 

 This rule applies when a patient is transferred directly to a postacute facility and when a patient goes home initially but is then admitted to a postacute facility within three days.

This week’s tip is adapted from The RAC Toolkit for Hospitals and Health Systems, published by HCPro, Inc.