Wednesday, October 26, 2016

CMS Rescinds Troubling SNF Benefit Policy Manual Language

Dan Ciolek
On September 16, 2016 the Centers for Medicare and Medicaid Services (CMS) published Transmittal 227 which included updated language to Chapter 8 of the Medicare Benefit Policy Manual that describes Coverage of Extended Care (SNF) Services. The policy update is effective October 18.

AHCA responded to CMS on September 26 and cited concerns that new policy language regarding the scope and purpose of Medicare’s post-hospital extended care benefit was confusing and appeared to conflict with existing Medicare law and regulations. The AHCA concerns centered on language pertaining to 1) the 3-day hospital stay requirement, 2) the definition of “skilled” services, 3) the 100-day stay benefit period, 4) the “intensity” of services, and 5) the absence of reference to the SNF as a “practical matter” requirement and “skilled maintenance” services. AHCA requested that the language be rescinded until the various concerns could be addressed.

On October 13, CMS published Transmittal 228 that rescinded the language that was of concern to AHCA while maintaining other changes that were not controversial. Additionally, CMS published a revised MLN Matters article MM 9748 that summarizes the policy correction, which includes the following statement:

“Language that was initially added by CR9748 in Transmittal R227BP to §20 of Chapter 8, regarding the scope and purpose of Medicare’s post-hospital extended care benefit, inadvertently included unclear wording and has been rescinded by Transmittal R228BP. As a result, the original version of this section’s text, as it read prior to that revision, is now restored.”

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