It is up to the SNF and the service provider to determine the specific terms and conditions of the SNF`s payment of the external entity (with respect to the amount at which the supplier or supplier is paid on what date). These agreements are a private matter between the NSF and the supplier or supplier. Medicare is not authorized to regulate how rules are made until anti-kickback statutes are violated. Knowing which services are excluded from the consolidated NFS regulation and which services are included is the most important step in ensuring an appropriate tally (Table 1). Lisa Gahara, Health Plan Manager and Billing Supervisor, New Hampshire Oncology-Hematology PA (Hooksett, NH), maintains a detailed list of services with columns for corresponding J-codes or CPT codes, billing unit and reimbursement source (Medicare or SNF). It changes the list based on information available on the cms website (www.cms.hhs.gov/SNFConsolidatedBilling/01_Overview.asp) and in regular editions of MLN Matters, an electronic CMS newsletter that provides updates for excluded services. For example, an edition of the May 2008 newsletter revealed that the injection of panitumumab (code J9303) had been added, retroactively to January 1, 2008, to the list of drugs excluded from the consolidated regulation. Gahara`s list allows him and other accountants and coders in the office to accurately charge for the services provided, but problems can still arise. She says a long list of unpaid bills to a local NWS led the NSF office manager to request a personal interview with oncology practice to sort out costs and discuss the possibility of developing a direct contract between the practice and the SNF. The article mln Matters « Skilled Nursing Facility (SNF) Consolidated Billing Service Furnished Under a « Arrangement » with an Outside Entity provides more details on the services provided by appointment. The external provider or supplier must verify its status in Part A or Part B before providing services with the recipient and the SNF. The supplier or supplier waives a separate Part B agreement for consolidated services and instead relies on the NSF for payment.
The provider or provider should inform all recipients of a Part A-covered SNF stay of the cb requirements for the services they receive. When an external agency submits a service subject to consolidated billing (CB), there should be an agreement in which the external entity applies the Skilled Nursing Facility (SNF) for the portions of its payment submitted to CB, not to the tax intermediary, the airline, the A/B Medicare Medicare Administrative Contractor or the beneficiary. Consolidated tally is a frequently used, but misunderstood, form of reimbursement of medical benefits in skilled care facilities.