Policy Analysis: Medicare Requires Two-Day Discharge Notification Facilities must give patients two days' written notice that services will end. Policy Analysis
Policy Analysis  |   August 01, 2013
Policy Analysis: Medicare Requires Two-Day Discharge Notification
Author Notes
  • Lisa Satterfield, MS, CCC-A is ASHA director of health care regulatory advocacy.
Article Information
Regulatory, Legislative & Advocacy / Policy Analysis
Policy Analysis   |   August 01, 2013
Policy Analysis: Medicare Requires Two-Day Discharge Notification
The ASHA Leader, August 2013, Vol. 18, 20. doi:10.1044/leader.PA2.18082013.20
The ASHA Leader, August 2013, Vol. 18, 20. doi:10.1044/leader.PA2.18082013.20
Under new and clarified regulations, therapy service providers in certain facilities must give Medicare patients at least two days' notice of treatment termination.
Since 2005, providers in home health agencies, comprehensive outpatient rehabilitation facilities, skilled nursing facilities and hospices have been required to notify patients who are being discharged from services. Recent updates to the Medicare Claims Processing Manual, Chapter 30, clarify the rules and make some changes to the skilled nursing facility notification, effective Aug. 26, 2013.
Two-day warning
Providers must give all Medicare beneficiaries in these facilities (or their representatives) a Notice of Medicare Non-Coverage, even if the beneficiary agrees with the termination. Providers may give the notice earlier than—but close to—two days before, and not when treatment begins (unless it's expected to last fewer than two days).
Providers are not required to give the notice if:
  • Services are reduced, rather than terminated. (For example, a beneficiary continues to receive Part A services in a skilled nursing facility, but some Part B services have been discontinued.)

  • A skilled nursing facility stay is not covered for lack of the beneficiary's qualifying hospital stay.

  • Home health services are not covered because the beneficiary did not have a face-to-face visit with a physician.

  • One therapy is ending but another is continuing.

  • The beneficiary is moving to a higher level of care or transferring to another provider at the same level.

  • A beneficiary reaches 100 days of coverage in a skilled nursing facility, exhausting Part A benefits.

  • A beneficiary chooses to end care.

  • Providers discontinue care for safety or business reasons.

Skilled nursing facilities
Because Medicare beneficiaries in skilled nursing facilities may receive Part A (inpatient) and Part B (outpatient) services, the notification rules are a bit more complex. The facility must provide a noncoverage notice at the end of a beneficiary's Part A stay or when all of the beneficiary's Part B services are ending. This situation could apply if a beneficiary exhausts the Part A 100-day skilled nursing facility benefit, and chooses to pay privately to remain in the facility. If this beneficiary receives therapies covered under Medicare Part B, the facility must provide a termination notice when all Part B services are coming to an end.
For notice of noncoverage information, instructions and format, visit the Centers for Medicare & Medicaid Services site.
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August 2013
Volume 18, Issue 8