The Office of Inspector General (OIG) just released a report about payments for ambulance transports of patients who reside in a Skilled Nursing Facility (SNF). The OIG audited 100 randomly selected beneficiary days that contained an ambulance claim line and found that for 78 of those days Medicare Part B made payments that were incorrect.
Refresher - 100 Day Stay:
Medicare pays for the first 100 days of a patient's stay in a SNF, also known as their Part A stay. While there are a few exceptions - such as ambulance transports for emergency care or transports to and from dialysis - most transports of Medicare SNF patients during their Part A stay should be billed to the SNF, not to Medicare.
Why Did These Overpayments Occur?
According to the OIG, the overpayments are the result of:
- Not understanding SNF Consolidated Billing rules
- Failing to find out what services the patient was transported to receive
- Failing to ask about the patient's Part A resident status
- MAC Recoveries- Medicare Administrative Contractors (MACs) are supposed to recover the overpayments identified in the OIG report that are within the 4 year reopening period.
- Provider Refunds- MACs will notify ambulance suppliers identified in the report as having potential overpayments that are outside of the 4 year reopening period.
- Referrals to the OIG- MACs have been instructed to refer ambulance providers with a pattern of incorrect billing to the OIG for additional enforcement action.
- Edits to the Common Working File- By April 2019, CMS plans to implement edits to prevent improper payments for ambulance transports of SNF residents.
What You Should Do:
- Check your mail. MACs have been recouping overpayments based on two 2018 OIG reports. So, we can expect the same recoupment effort in response to this Report.
- Audit your claims. The OIG Report puts you on notice of potential overpayments. Review any claims where the origin or destination was a SNF to determine if the proper payer was billed.
- Evaluate how you determine if Medicare Part B or the SNF is responsible to pay for transports of SNF residents. Are you asking the right questions?
Need help? We'll cover the questions you should be asking your SNFs along with the latest updates on the OIG's enforcement activity at abc360!