Jeannine LeCompte, Publishing and Research Coordinator
Another component of the financial integrity legal obligation upon Medicare- and Medicaid-approved skilled nursing facilities (SNFs) is to have a policy in place to ensure that all cost reporting procedures are correct before final billing is submitted to the Centers for Medicare & Medicaid Services (CMS).
This policy must ensure that there is a triple-checked verification of all claims and their supporting data before a submission is made. This is vital to prevent the submission of false or incorrect claims, which inevitably result in sanctions.
The policy requires input and cross-correlation from all the SNF’s service departments, including administration, the therapy and nursing units, the minimum data set (MDS) coordinator, and the clinical manager.
It is a business office task to ensure that each resident meets the basic submission requirements. These include a check through the common working file to make sure the resident has Medicare benefit days available; that all qualifying stays listed on the uniform billing form (UB-04) correspond with medical record dates; that all residents’ names, social security numbers, and Medicare numbers are accurate and verified, and that all other administrative logs are up to date and accurate.
In addition, the assigned staff person must ensure that all Notice of Medicare Non-Coverage (NOMNC) submissions are made, and that vendors do not double bill Medicare for services already included in the SNF’s submission.
It is also important to ensure that no Medicare claims are made by working age Medicare beneficiaries who are covered by an employer group health plan or some other insurance.
The service departments—that, is the therapy and nursing divisions—must ensure that all records of treatment are complete and accurate and tally with all billing data. This includes the guarantee that all documentation which supports any intervention is complete and on record, and that any procedures ordered therein have been carried out in full.
Finally, once all this data has been collected, it must be presented to an interdepartmental committee meeting for verification and sign-off before the final billing process is started. This process needs to be part of a regular routine, and all work should be completed well before the billing due date to allow time to correct any discrepancies which may be spotted.
