On March 11, 2010, CMS held one of its regular SNF Open Door Forums. The following is a summary of the forum.
CMS is holding a MDS 3.0 National Train-the-Trainer Conference on April 13-15 at the Radisson Plaza Lord Baltimore Hotel. While this session is full, CMS is looking to provide additional sessions to accommodate the number of people who were unable to register. About 950 people attempted to register but there was space for only 250. CMS has created a waiting list in the event of cancellations. In addition, CMS is investigating the possibility of providing video of the conference. Additional announcements will be made in the next few weeks.
CMS has investigated complaints from SNFs that hospitals are retroactively changing their claims from an inpatient to an outpatient stay after the patient has been discharged to a SNF. Hospitals have been advised that admissions will be reviewed to ensure that inpatient admissions are medically necessary. CMS also noted that admissions that are made for social reasons should not be paid at the inpatient rate. CMS also clarified that the review of inpatient claims will not affect payments for SNFs who admit patients in good faith after a qualifying hospital stay. CMS said that SNFs that exercise reasonable precautions to ensure a SNF stay is warranted would not have problems with their claims.
A number of callers asked about the status of the revised SNF ABN. CMS reported that the form is still under review and that an implementation date has not been set.
§ A caller asked if a SNF could deny a patient based on the estimated costs of providing care. CMS said a SNF could deny a patient if the level of care required exceeds the SNFs capabilities, but may not deny care due to cost concerns.
§ A caller expressed concern that a SNF was taking on considerable expense by treating a patient with particularly costly injectible drug that is not excluded from consolidated billing. CMS noted that the consolidated billing requirements are based in statute. However, CMS added that it is considering refinements to the SNF case-mix adjustments to account for high cost prescription drugs. CMS did not have additional details and noted that a proposal is not ready yet.
§ A caller asked what form should be used to notify a patient that their services do not qualify for an exception to the therapy cap. CMS said that form CMS-R-131 should be used.
§ A caller asked how a SNF should determine the end date for Medicare services. Specifically, the caller asked if it should be the date of discharge or the last day skilled care was provided. CMS will address this issue on the next open door forum.
The next SNF open door forum is scheduled for Thursday, April 22, 2010.