Consolidated Billing Regulations for Skilled Nursing Facilities (SNFs)
With the implementation of the Consolidated Billing regulations for Skilled Nursing Facilities (SNFs), many freestanding oncology centers are receiving denials for radiation therapy provided to SNF patients. Section 205 of the Skilled Nursing Facility 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.” No provision is made in the regulations for transfer to freestanding facilities for radiation treatment, diagnostic imaging, etc.
While it may be possible for a freestanding center to establish an agreement with a SNF and obtain reimbursement for the technical component directly from the nursing facility, most SNFs will not enter into such an agreement since they cannot receive Medicare reimbursement for these purchased technical services. The omission of freestanding centers from this transfer agreement is not a commentary on the care provided in any specific location, but centers around prospective payment reimbursement. Both the SNF and outpatient hospital are currently reimbursed under different Prospective Payment Systems (PPS), where the freestanding centers are paid under the Medicare Physician Fee Schedule.
Freestanding centers should ensure that potential patients residing in a nursing facility have the necessary technical component reimbursement agreement with the SNF, or advise the facility that these patients must be referred to a hospital outpatient program for therapy.
Cindy C. Parman, CPC, CPC-H
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.