How Do I Document Medicare Part A in Skilled Nursing Facilities? SNF services may be covered under Medicare Part A or B. Here’s what you need to know about Part A services. Bottom Line
Free
Bottom Line  |   August 01, 2015
How Do I Document Medicare Part A in Skilled Nursing Facilities?
Author Notes
  • Tim Nanof, MSW, is director of ASHA health care policy and advocacy. tnanof@asha.org
    Tim Nanof, MSW, is director of ASHA health care policy and advocacy. tnanof@asha.org×
  • Lisa Satterfield, MS, CCC-A, is director of ASHA health care regulatory advocacy. lsatterfield@asha.org
    Lisa Satterfield, MS, CCC-A, is director of ASHA health care regulatory advocacy. lsatterfield@asha.org×
Article Information
Special Populations / Older Adults & Aging / Healthcare Settings / Practice Management / Bottom Line
Bottom Line   |   August 01, 2015
How Do I Document Medicare Part A in Skilled Nursing Facilities?
The ASHA Leader, August 2015, Vol. 20, 34-35. doi:10.1044/leader.BML.20082015.34
The ASHA Leader, August 2015, Vol. 20, 34-35. doi:10.1044/leader.BML.20082015.34
Skilled nursing facilities (SNFs) provide services to Medicare beneficiaries under Part A (inpatient) and Part B (outpatient). SNF patients in the first 100 days of a post-acute episode are covered under Part A. Beneficiaries who have used up their inpatient days or don’t qualify for Part A coverage receive services under Part B.
The combination of Part A and Part B rules in SNFs, along with the requirements of the Minimum Data Set (MDS)—the data collection system used as the basis for Part A billing in long-term care facilities—causes confusion for many speech-language pathologists documenting their skilled services. Here are some Part A pointers.
What can I count in my MDS minutes?
Therapy time is recorded in the MDS in one-minute increments, and includes:
  • Skilled therapy time with the patient.

  • Assessments of the conditions under the plan of care.

  • Family education when the resident is present.

  • Time required to adjust equipment and prepare treatment area.

The initial evaluation necessary to develop the plan of care and time spent on documentation (even if the patient is present) is not included in the MDS treatment minutes.
How do I calculate my time for individual, group, concurrent and co-treatment?
The MDS software will automatically calculate the minutes per patient according to the type of therapy you document. SLPs should document the total time spent in the treatment session. The MDS will then make the following adjustments based on your selection:
  • In individual treatment, all the minutes are all assigned to the patient receiving treatment.

  • For concurrent therapy (simultaneous treatment of two residents who are not performing the same or similar activities), each patient is assigned half the minutes.

  • For group therapy (treatment of two to four residents performing the same or similar activities), each patient is assigned one-fourth of the minutes, regardless of the number of participants.

  • For co-treatment (two clinicians from different disciplines provide simultaneous, different treatment to one resident), the patient is assigned the full amount of time for both disciplines.

Why am I allowed only 15 minutes to evaluate a resident?
Medicare does not limit the time for evaluations—that is an administrative decision by the facility. Limiting an evaluation runs counter to standards of practice for completing a thorough assessment.
This myth is perpetrated because managers mistakenly interpret payment policies. The base reimbursement rate for an SNF patient includes the evaluation time, but managers may interpret the policy to mean that facilities are not reimbursed for evaluations. In fact, the base rates were calculated to include the evaluation, with the expectation that the comprehensive evaluation will provide the information necessary to develop a plan of care or diagnose the patient.

Medicare does not limit the time for evaluations—that is an administrative decision by the facility. Limiting an evaluation runs counter to standards of practice for completing a thorough assessment.

If I need to extend my evaluation over two days because the patient tires, do the minutes on the second day count in the MDS?
If the initial evaluation is not completed on one day and there is not enough information to develop a plan of care, the minutes for the second day should not count in the MDS. Once the plan of care is established and treatment begins, minutes spent assessing patient progress may be counted in the MDS.
If I am already treating a patient for cognition, and swallowing issues later develop, is the evaluation of swallowing an initial evaluation or re-evaluation?
The initial evaluation did not reveal concerns with swallowing or inform a plan of care for swallowing. The swallowing episode is not related to the current plan of care and, therefore, is not a re-evaluation of a current condition or disorder. The swallowing assessment is considered an initial evaluation, because data collection is necessary to develop a plan of care or diagnose the patient, so the minutes do not count in the MDS.
How do I code the Part A re-evaluation if it’s part of my treatment session? Is it OK to use the evaluation CPT codes, or should I use the treatment code?
There are no Medicare requirements for the use of CPT codes (Current Procedural Terminology ® American Medical Association) for Part A services. You may use the most appropriate code(s) in your documentation—in fact, many documentation systems require you to include the codes. But in reality, only the minutes—not the codes—are required for Medicare billing.
Many facilities, however, require clinicians to submit CPT codes for internal productivity reasons. Your documentation should always be consistent with—and demonstrate medical necessity for—the skilled services you provided. It’s appropriate to use the treatment codes for re-evaluations that are part of the treatment session, as assessment is considered a part of treatment and a skilled service.

Your documentation should always be consistent with–and demonstrate medical necessity for–the skilled services you provided.

My supervisor instructed me to bill units (15-minute increments) for CPT 92507, but I thought this was a session-based code. What should I do?
CPT 92507 (individual treatment of speech, language, voice, communication and/or auditory processing disorder) is a session-based code used for Part B (outpatient) services, and may be billed in one unit. Your facility’s documentation system may be programmed to be consistent with the physical therapy and occupational therapy treatment codes, requiring you to bill units for 92507. The Part A claim does not need the CPT code, only the exact number of minutes you provided the treatment. Check with management regarding the programming of the documentation system.
Correction
The July 2015 Bottom Line column, “The Latest on Medicare Coverage of SGDs” (on.asha.org/sgdcoverage) indicated that Medicare’s capped rental policy for speech-generating devices will be lifted Oct. 1. In fact, this change is dependent on legislation that has passed the Senate and the Committee of jurisdiction in the House. The House is expected to pass the law before adjourning for the August recess.
0 Comments
Submit a Comment
Submit A Comment
Name
Comment Title
Comment


This feature is available to Subscribers Only
Sign In or Create an Account ×
FROM THIS ISSUE
August 2015
Volume 20, Issue 8