The Centers for Medicare and Medicaid Services (CMS) Supplemental Medical Review Contractor (SMRC) has recently announced that they have initiated a special medical review study of SNF Medicare Part A Therapy Services. Per the SMRC website, Project Y4P0432 – Skilled Nursing Facility (SNF) Therapy Services (08/11/16) was requested by CMS based upon the findings of a recent Office of Inspector General (OIG) report entitled Skilled Nursing Facility Billing for Changes in Therapy: Improvements are Needed, OEI-02-13-00611. In this study, the OIG evaluated how SNFs utilized three new Minimum Data Set (MDS) patient assessments that were implemented in FY 2011 and 2012 to better reflect the amount of therapy provided. The new assessments better capture when beneficiaries start therapy, end therapy, and decrease or increase therapy significantly enough to impact the Resource Utilization Group (RUG) payment case mix. In the report, published June 2015, the OIG suggested that some SNFs may be using the new assessments incorrectly, which could result in improper payments.
Per the SMRC website, as directed by CMS, Strategic Health Solutions will conduct post payment medical review of the SNF Therapy services. The details of how many SNF providers will be reviewed was not provided. However, the SMRC did provide a link to an example Additional Documentation Letter for this study.