Reimbursement Update
2009 Medicare Cost Reporting
New Medicare PS&R System
ABN Modifiers Updated
The recently passed health care reform package included many provisions that affected the Medicare Part A payment system for skilled nursing facilities. The expansion of the RUGs payment system from 53 groups to 66 groups (RUG-IV) will not take effect until October 1, 2011, a year later than originally proposed by the Centers for Medicaid and Medicare Services (CMS). However, Congress did not delay the changes to concurrent therapy rules, the removal of the hospital look-back period or the introduction of MDS 3.0. These three changes will take effect October 1, 2010 as originally planned.
On the Medicare Part B side, the health care reform package extended the therapy caps exception process through December 31, 2010. Facilities can continue to add modifiers to their claims for qualifying individuals to be paid above the caps. Unfortunately, Congress did not include a fix to the Part B physician fee schedules in the package. President Obama recently signed legislation to prevent the potential 21.5% reduction to the fee schedules until May 31, 2010. If further action is not taken, the fee schedules for therapy services will be significantly lowered effective June 1, 2010. We will keep you updated with any breaking news regarding the fee schedules.
Calendar year 2009 Medicare cost reports are due June 1, 2010. As a reminder, any facility claiming reimbursement for coinsurance bad debts must file a “full” cost report. Facilities with less than $200,000 in Medicare reimbursement that are not claiming coinsurance bad debts may continue to file a low utilization report.
National Government Services (NGS) continues to audit claims for coinsurance bad debts for facilities requesting reimbursement. Providers should be careful to ensure that proper procedures and documentation are in place for all coinsurance bad debt claims. Upon review of the 2008 cost reports, NGS began to enforce a $50,000 bad debt threshold to receive pass-through payments. Any facility with coinsurance bad debt claims of less than $50,000 will no longer receive a bi-weekly pass-through payment. Please contact us if you have questions regarding bad debt reimbursement or need help completing your Medicare cost report.
Effective with fiscal years ending after January 31, 2009, all Medicare providers were required to register for the new Summary Provider Statistical and Reimbursement (PS&R) report system that would allow them to download their reports. However, many providers are continuing to struggle with the registration process and accessing the new system. As a result, NGS has recently begun sending PS&R reports to providers who are not yet registered in order to allow facilities sufficient time to prepare their Medicare cost reports; however, they have stated that the summary reports will not be sent again and facilities must obtain the reports directly from the new system in the future. Please contact us if you have any questions regarding the system or have not received your reports.
The Centers for Medicaid and Medicare Services (CMS) recently issued an update to two modifiers related to Advance Beneficiary Notices (ABNs). Modifier “-GA” (Waiver of Liability Statement Issued as Required by Payer Policy) must be used when a required ABN was issued. Modifier “-GX” (Notice of Liability Issued, Voluntary Under Payer Policy) must be used when a voluntary ABN was issued.
Effective April 1, 2010, Medicare claims billed without the correct modifier may be denied by CMS. Billing departments must be able to recognize when to use the correct modifier so that claims are processed correctly. Failure to do so could have a significant effect on your facility’s cash flow. Additional details and instructions on the use of these modifiers can be found on the CMS website.
Below are a few resources for the ABN Modifiers: