Medicare Compliance & Reimbursement

Rule could increase revenue for SNFs and improve access to care.

Come November, Medicare will cover something it hasn't before: Medically necessary visits by non-physician practitioners (NPPs) prior to an initial visit by the physician.
 
Old way: Until the Centers for Medicare & Medicaid Services issued Change Request 3096, the agency admits that its definition of "initial" physician visit was less than clear. That in turn meant that NPPs, namely physician assistants and advance practice nurses, weren't allowed to see patients before an "initial" visit by a physician, even if such care was medically necessary.
 
New and improved way: To improve access to care for residents in SNFs, CMS has said it will define "initial visit," aka comprehensive assessment, according to Survey and Certification memo 04-08 ("Physician Delegation of Tasks in Skilled Nursing Facilities and Nursing Facilities"). Once that change is official - effective Oct. 25 - NPPs can provide paid services to nursing facility patients prior to and after the initial physician visit.
 
That's important news for facilities who employ NPPs, notes Elizabeth Malzahn of FR&R Healthcare Consulting in Deerfield, IL. Keep these tips in mind to ensure compliance with the new regs and coding requirements:

  Medicare will pay only a physician for the initial visit.   Medicare will pay NPPs to provide annual assessments (other than the initial visit), readmissions assessments or major-change-in-status evaluations.   Clinical nurse specialists and nurse practitioners employed at a SNF or NF may reassign payment to the facility.   When a nursing facility employs a physician assistant, the facility must bill the Medicare carrier for the professional service component using the PA's UPIN.   Carriers will deny any claims for NPP services billed with CPT codes in the 99301-99303 range (comprehensive evaluation and management visit in a SNF or NF) before the initial visit and reporting by the physician. To review updated manual instructions, go to www.cms.hhs.gov/manuals/transmittals/comm_date_dsc.asp.