On November 16, the Centers for Medicare & Medicaid Services (CMS) issued a provider compliance alert for skilled nursing facilities (SNFs), advising them to ensure they are using appropriate place of service (POS) and other codes. SNFs should also review the revised SNF 3-Day Rule Billing fact sheet, which is available here.
Hospitals, including critical access hospitals (CAHs), should correctly communicate the number of inpatient days to SNFs and patients (or their representatives) to ensure all parties fully understand their potential payment liability. SNF extended care services coverage applies if a patient has a qualifying inpatient stay of at least 3 consecutive calendar days starting with the admission day but not counting the discharge day.
To qualify for skilled nursing facility (SNF) extended care services coverage, Medicare patients must meet the 3-day rule before SNF admission. The 3-day rule requires that the patient have a medically necessary 3-consecutive-day inpatient hospital stay, which does not include the discharge day or pre-admission time spent in the emergency room (ER) or outpatient observation. The 3-day rule also applies to hospitals and CAHs approved to provide swing bed services for acute care or post-hospital SNF services. SNF extended care services extend a patient’s care after a hospital or swing bed discharge or within 30 calendar days of their hospital stay (unless admitting them within 30 calendar days is medically inappropriate). SNFs must use occurrence span code 70, a code used to report qualifying stay dates for SNF use only, to report qualifying hospital stay dates of at least 3 consecutive calendar days, not counting the discharge date.
The OIG report can be found here.
Compliance Perspective
Issue
Improper payments can occur when a hospital discharges an inpatient before they meet the 3-day rule and the SNF admits them for extended care services. Hospitals must correctly understand the 3-day rule to give accurate inpatient stay information and dates to SNFs and patients. SNFs must correctly understand the 3-day rule to avoid inappropriately submitting claims that don’t meet the 3-day rule.
Discussion Points
- Review your policies and procedures to determine if revisions are needed to ensure accurate application of the 3-day stay rule and related coding. Update if necessary.
- Train appropriate staff on how to accurately code Medicare Part A stays, to determine when a person meets the 3-day qualifying stay rule, and the steps to follow both when they do and when they do not meet that 3-day stay requirement. Document that the training occurred and place in the employees’ training files.
- Periodically audit to ensure that coding is accurately completed by those individuals who have responsibility for inputting data at your facility, that the 3-day qualifying stay is correctly calculated, and that appropriate related notifications are provided to the patient and/or representative. Determine that staff have the most current CMS guidance, and that they are using it.
*This news alert has been prepared by Med-Net Concepts, LLC for informational purposes only and is not intended to provide legal advice.*
