CMS Reminds SNFs of the Importance of Accurate Use of Codes for 3 Day Qualifying Rule.

• By: Maureen Carland
• On: 12/12/2023 08:27:18
• In: Quality/Regulatory

The Centers for Medicare & Medicaid Services (CMS) has issued a provider compliance alert aimed at skilled nursing facilities (SNFs). The alert advises SNFs to ensure they are using the correct place of service (POS) and other codes. SNFs are also encouraged to review the updated SNF 3-Day Rule Billing fact sheet.
Hospitals are urged to accurately communicate the number of inpatient days to both SNFs and patients (or their representatives). This is to ensure that all parties have a clear understanding of their potential payment responsibilities. SNF extended care services coverage is applicable if a patient has undergone a qualifying inpatient stay of at least 3 consecutive calendar days, beginning with the admission day but excluding the discharge day.
SNFs are required to utilize occurrence span code 70, a code specifically for reporting qualifying stay dates for SNF use, to report qualifying hospital stay dates of at least 3 consecutive calendar days, excluding the discharge date.
From a compliance perspective, the key issue is the potential for improper payments when a hospital discharges an inpatient before they meet the 3-day rule, and the SNF admits them for services. SNFs must also have a thorough grasp of the 3-day rule to avoid submitting inappropriate claims that do not align with the 3-day rule. See OIG report.
Compliance actions you might consider:

• Review your policies and procedures to ensure the accurate application of the 3-day stay rule and related coding.
• Providing training on how to accurately code Medicare Part A stays, determine when a person meets the 3-day qualifying stay rule, and outline the necessary steps when they meet or do not meet that 3-day stay requirement.
• Conduct periodic audits to verify that coding is being accurately completed by individuals responsible for data input at your facility, that the 3-day qualifying stay is calculated correctly, and that appropriate notifications are provided to the patient and/or representative.
• Confirm that staff have access to the most up-to-date CMS guidance and that they are using it.

 
Staff Contact: mcarland@mehca.org