Stacey A. Borowicz

Overpayments to Skilled Nursing Facilities on the Rise

September 25, 2014Articles

Nearly $2.5 billion dollars in overpayments were made to Skilled Nursing Facilities (“SNFs”) as a result of billing errors last year. The billing error rate for SNFs jumped to 7.7 percent, virtually doubling in 2013. According to CMS, the majority of these billing errors arise from the SNF’s repeated failures to obtain necessary certification and re-certification statements from physicians and non-physician providers (collectively “Providers”).

Where necessary, SNFs should ensure that acceptable certification and re-certification statements are obtained from all Providers. According to the August 25, 2014 CMS Bulletin, certification and recertification statements must meet the following elements in addition timing requirements:

  1. The individual requires skilled nursing facility care or other skilled rehabilitation services;
  2. Services are required on a daily basis;
  3. Services can only be practically provided by a SNF;
  4. Services are for an ongoing condition for which the individual received inpatient hospital care; and
  5. Dated signature of the certifying Provider.

CMS also clarified the requirements for acceptable re-certification statements as follows:

  1. Reason(s) for continued need for SNF care;
  2. Estimated time the individual will need to remain in SNF;
  3. Plans for home care (if any);
  4. If the reason for continued care arose after admission to the SNF; and
  5. Dated signature of the re-certifying Provider.

For more information, carefully review CMS’s Bulletin, MLN Matters Number SE1428 dated August 25, 2014, by clicking here. For further questions, or to ensure your facility is meeting its obligations properly, contact a member of Dinsmore’s Healthcare Practice Group.