June 12, 2020
Skilled nursing facilities (SNFs) can count minutes of therapy provided via telehealth technologies for Medicare Part A on the Minimum Data Set (MDS), according to the Centers for Medicare & Medicaid Services (CMS). On May 28, 2020, CMS stated the following in a frequently asked questions document:
Question: Can therapy services furnished using telecommunications technology be paid separately in a Medicare Part A skilled nursing facility (SNF) stay?
Answer: Provision of therapy services using telecommunications technology (consistent with applicable state scope of practice laws) does not change rules regarding SNF consolidated billing or bundling. For example, Medicare payment for therapy services is bundled into the SNF Prospective Payment System (PPS) rate during a SNF covered Part A stay, regardless of whether or not they are furnished using telecommunications technology. Therapy services furnished to a SNF resident, whether in person or as telehealth services, during a non-covered SNF stay (Part A benefits exhausted, SNF level of care requirement not met, etc.) must be billed to Part B by the SNF itself using bill type 22X regardless of whether or not they are furnished using telecommunications technology.
In a subsequent email from CMS staff to the National Association for the Support of Long-Term Care (NASL), CMS confirmed that these minutes can count on the MDS. As always, these services must meet the definition of skilled care for SNFs as outlined in Chapter 8 of the Medicare Benefit Policy Manual [PDF].
ASHA provides coding and billing guidance for Medicare telehealth services during the public health emergency. Contact firstname.lastname@example.org for additional information.