Expect SNF Medicare denial letters to rise precipitously Meanwhile, OIG has shown no signs of relenting in its scrutiny of SNFs, noting in its 2011 Work Plan that: The message to Medicare contractors is crystal clear: SNFs, especially those that have a significant placement rate for “Ultra High” therapy RUGs, should be increasingly targeted for audits. ![]() Contractors could use their findings to recover inappropriate payments, to place certain SNFs on prepayment review, and to initiate fraud investigations. Contractors could conduct medical reviews of a sample of claims from SNFs that exceed these thresholds. If SNFs from a particular chain frequently exceed these thresholds, then additional reviews should be conducted of the other SNFs in that chain.Ĭontractors should use this information to target their efforts to more effectively identify and prevent inappropriate billing. CMS should develop thresholds for each of these measures and instruct contractors to conduct additional reviews of SNFs that exceed them. Specifically, the contractors should determine for each SNF: (1) the percentage of RUGs for ultra high therapy (2) the percentage of RUGs with high ADL scores, and (3) the average length of stay. HHS-OIG then outlined several recommendations based on its conclusions, one of which entailed increased oversight of SNFs that bill for higher paying RUGs:ĬMS should instruct its contractors to monitor the SNFs billing for higher paying RUGs using the indictors discussed in this report.
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