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Can you explain the Interrupted Stay and how it impacts Medicare billing?

When a resident discharges from a Part A covered stay and subsequently resumes skilled care in the same skilled nursing facility during the interruption window, the readmission is treated as a continuation of the previous covered stay. The interruption window is defined as the first non-covered day, including the two immediately following days ending at 11:59 p.m. 

When the Interrupted Stay policy applies, there is no need to complete a new PPS 5-Day assessment for billing, as the original stay is continuing after a brief interruption and the per diem rate has already been established. Conversely, if a resident returns to the SNF for a Part A covered stay after the interruption window has passed, a new PPS 5-Day assessment will be necessary to establish the per diem rate for the new stay. 

While simple in theory, execution of this policy can be tricky in certain situations and requires a close eye on the calendar. If, for example, there is not a clear understanding of the interruption window, a required PPS 5-Day assessment may be inadvertently missed, leading to billing complications. 

If the SNF fails to set the ARD of a 5-Day assessment prior to the end of the last day of the ARD window, and the resident was already discharged from Medicare Part A when this error is discovered, the provider cannot complete an assessment for SNF PPS purposes and the days cannot be billed to Part A.

If the resident is still on Part A when the error is discovered, the SNF must complete a late assessment. The ARD can be no earlier than the day the error was identified and the SNF will bill the default rate for the number of days that the assessment is out of compliance.

Better late than never, but attention to census and payor changes is key to avoiding MDS scheduling snafus.