Thursday June 23, 2011
A summary and suggestions regarding the Office of
Inspector General's Report on billing practices in
Skilled Nursing Facilities
In December, 2010, the OIG issued a report on Medicare Part A
services provided in the SNF setting. This summary addresses the
findings along with suggestions.
In the recent past the OIG has found a number of issues with SNF
billing for Part A services. One such report analyzing claims from
2006-2008, found that 26% of claims submitted were not
supported by the medical records resulting in over $500
million in potential overpayments. Along with these findings, the
Medicare Payment Advisory Commission indicated that SNFs may be
improperly billing for therapy in order to obtain
additional Medicare payments.
- SNFs were increasingly billing for higher paying RUGs, even
though the beneficiary characteristics remained almost the
- For-profit SNFs were more likely to bill higher paying RUGs
than nonprofit and government SNFs.
- Some SNFs had questionable billing in 2008, frequently
billing for higher RUGs and having longer length of stays (LOS)
than other SNFs.
These findings raised concerns about the potentially
inappropriate use of higher paying RUGs, especially the Ultra High
category and deduced that the payment system offered incentives to
place beneficiaries into these categories when that level of care
was not needed. The report acknowledged that a new payment system
was being introduced but felt that more needed to questionable
If you are not sure if you are up to date with the Medicare
guidelines and documentation standards or whether your SNF would
pass a RAC Audit or other OIG or CMS review, then consider looking
for related regulations, guidelines, MDS analysis on LTC Provider
here for a copy of the Full Report