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How No Pay Bills Will Affect Part B Therapy Claims

Providers continue to have questions regarding regulations of the Consolidated Billing (CB) requirement, established initially as specified in the Balanced Budget Act of 1997.  Each year, the Centers for Medicare and Medicaid (CMS) issue updates to CB to further clarify the regulations or to revise the services that are considered excluded (or included) in the rules.

Change Request (CR) 5757 dated 11/2/07 further clarifies additional Common Working File (CWF) editing for SNF Consolidated Billing to ensure that all therapy services are subjected to SNF CB edits when provided in a covered or non-covered SNF stay. The effective date of these edits was April 7, 2008.

According to MLN Matters # MM5757, “Since therapy services provided in a SNF must be consolidated when a beneficiary is in a SNF stay , whether covered or non-covered by Medicare, Medicare systems will reject claims within dates of service falling within a SNF stay. As a result of this specific change, Medicare’s CWF system will reject claims with dates of service after the posted SNF claim until a discharge claim is processed. The entity furnishing the therapy services must look to the SNF for payment, rather than billing Medicare.”

With the issuance of CR 5757, nursing facilities must file the no-pay claim monthly for residents who are receiving Part B therapy services in the nursing facility. For example; resident Jane Doe utilizes 60 Medicare Part A benefit days at which time she is cut from a skilled level of care. The facility must “end” the benefit period for Jane Doe with a 213 bill type, a 30 status code (still a resident) and an occurrence code 22, indicating the last covered day of skilled care. At this time, the facility had the option of filing no-pay claims each month OR filing a final no-pay claim upon the resident’s permanent discharge from the facility. If the no-pay claim is not filed, the Medicare system will reflect that the resident remains in a skilled stay and the Part B therapy claims will be rejected.

Official instruction (CR5757) can be found at:
http://www.cms.hhs.gov/transmittals/downloads/R1365CP.pdf

Further information on Consolidated Billing can be found at:
http://www.cms.hhs.gov/SNFConsolidatedBilling/