Oncology Coding Article-Freestanding Radiation Therapy Centers

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Freestanding radiation therapy centers are still encountering difficulty with the reimbursement for the technical services of radiation treatment provided to nursing home patients. 

When a patient is considered to be an inpatient in a hospital, and is conveyed to a freestanding radiation center to receive treatment that is not available in the hospital, the center generally has a contract in place to receive reimbursement for the technical component of the radiation treatments delivered. The professional services associated with the radiation therapy can be directly billed to the payor, with the place of service ‘inpatient hospital.’ Of note, the place of service is listed as the patient’s place of service, or current patient status, not the location of the treatment delivery. While the hospital receives reimbursement for all technical services provided to the patient during the inpatient stay through Medicare DRG (Diagnosis Related Groups) allowances, this concept does not apply to nursing facilities.

Section 201.2 of the Skilled Nursing Facility (SNF) Manual states: “To participate in the program, a SNF must have a written transfer agreement with one or more participating hospitals providing for the transfer of patients between the hospital and the SNF, and for the interchange of medical and other information.” Based upon this information, a freestanding radiation treatment center cannot bill Medicare directly for the technical component of services when a patient is transferred from a skilled nursing facility to the center for therapy. However, reimbursement may be received if the freestanding center contracts with the SNF for direct payment of the technical services to the center. This is difficult at best, since the SNF also cannot bill Medicare for the technical services ‘purchased’ from the center, and is under no obligation to sign a contract.

As a result, freestanding centers should consider adopting a policy regarding treatment of SNF patients, and ensure the existence of a contractual relationship with the nursing home prior to the delivery of therapy.

Cindy C. Parman, CPC, CPC-Hcparman-9236846
principal and co-founder of Coding Strategies, Inc. in Atlanta, GA. Cindy is a current member of the Advisory Board for the American Academy of Professional Coders (AAPC) and a faculty instructor for AMA Solutions, a subsidiary of the American Medical Association.  She serves as the Consulting Editor of the Radiology Coding Alert and is on the Editorial Advisory Board of General Surgery Coding Alert and Pain Management Coding Alert.  

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