Tuesday, March 31, 2015

SGR Vote Delay Is No ‘April Fool’s Day’ Joke for Part B Therapy – What SNF Providers Need to Know

Dan Ciolek

Facility operators are entering a period of operational uncertainty and risk related to Medicare Part B services due to the U.S. Senate's not voting on a new Sustainable Growth Rate (SGR) bill - also known as the Doc Fix - prior to the March 31 expiration of the current SGR and therapy cap exceptions process. While we are cautiously optimistic the bill will be enacted when the Senate returns from recess in mid-April, there are no guarantees. Also, the delay has created some operational challenges providers need to consider. There are two major issues that we want to alert you to and provide preliminary recommendations, as there is no current guidance from the Centers for Medicare and Medicaid Services (CMS).

First risk - Under current law, a -21.2 percent adjustment would apply to the Part B fee schedule effective April 1. However, if the Senate passes the SGR bill, this cut will not apply. To mitigate this risk, AHCA recommends that SNF operators hold any Part B claims with dates of services on or after April 1 until it is clearer what will happen in the Senate.

 Second risk – Under current law, the therapy caps exceptions process expires on March 31 and there will be a hard $1,940 therapy cap with no exceptions. Beginning April 1, there will be payment liability risks for services furnished above the cap threshold. However, if the SGR bill is enacted when the Senate returns from recess, this will not apply. To mitigate this risk, AHCA recommends that SNF operators issue Advance Beneficiary Notices (ABNs) to beneficiaries needing Part B therapy services beyond the $1,940 threshold as of April 1, 2015.

AHCA has prepared a detailed FAQ document based upon current available information that has been reviewed and commented on by the AHCA Finance Committee's Billing and Operations Subcommittee and the Therapy Policy Advisory Group. We encourage SNF operators to review and consider these recommendations within the context of their current operational policies.

For additional questions please contact Dan Ciolek, AHCA Senior Director, Therapy Advocacy at dciolek@ahca.org.

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