According to a recently released memorandum from CMS, the rate of improper Medicare payments to skilled nursing facilities has significantly increased because of issues with certification and recertification statements. The CMS document summarizes requirements that all SNF physicians, non-physician practitioners (NPPs) and billing staff must meet for compliance. According to the memo, between 2012 and 2013, SNF improper payment rates increased from 4.8% to 7.7%. Because of SNFs failure to get proper certification/recertification from physicians and NPPs, there were drastically more improper payments. Among other requirements, “an acceptable certification statement must establish that the resident needs skilled nursing care or skilled rehabilitation services on a daily basis.” Acceptable recertification statements must document the reasons why a resident continued post-hospital skilled care and the estimated time the resident will remain in the SNF. The memo also states that physicians alone can certify outpatient physical therapy and outpatient speech-language pathology services. Additionally, the memo includes information on how and when to document certification/recertification statements.
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