CMS: Many skilled nursing providers have poor Medicare certification and recertification practices

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Regulators to double down on QAPI after government report on adverse events in post-acute care
Regulators to double down on QAPI after government report on adverse events in post-acute care

The rate of improper Medicare payments to skilled nursing facilities has increased largely due to issues with certification and recertification statements, according to a recently released government memorandum. The Centers for Medicare & Medicaid Services document summarizes requirements that SNF physicians, non-physician practitioners (NPPs) and billing staffs must meet for compliance.

Between the 2012 and 2013 reporting periods, the SNF improper payment rate jumped from 4.8% to 7.7%, the memo states. SNFs' failure to get proper certification/recertification from physicians and NPPs is a “major source” of improper payments, according to Comprehensive Error Rate Testing findings.

The memo notes that, among other requirements, an acceptable certification statement must establish that the resident needs skilled nursing care or skilled rehabilitation services on a daily basis. An acceptable recertification statement must document the reasons why a resident has a continued need for post-hospital skilled care and the estimated time the resident will remain in the SNF, among other requirements.

Physicians alone may certify outpatient physical therapy and outpatient speech-language pathology services, the memo emphasizes.

The document also includes information on how and when to document certification/recertification statements, and timeframes for when they must be obtained.

Click here to access the complete memo, originally transmitted via email on Aug. 20. 

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