Ensuring Compliance with Financial Business Practices: Billing Routines

Jeannine LeCompte, Publishing and Research Coordinator

Skilled Nursing Facilities (SNFs) are required to ensure that all financial processes are in alignment with the compliance regulations as specified by the Centers for Medicare & Medicaid Services (CMS). The best way to ensure compliance is for SNFs to have a series of regular billing routines which check all aspects of the process. In this way, any errors or issues can be detected in the quickest possible time and dealt with before they become serious.

It is advisable to start with a daily check. The admissions office should perform a manual census of all new admissions or readmissions, discharges, and status changes. This census forms the basis of all further activity overviews, and if regularly maintained, is not overly onerous.

Then on a weekly basis, the Minimum Data Set (MDS) coordinator should submit the MDS software’s “Transmittal Batch Report” and Patient-Driven Payment Model (PDPM) Classification Resident Summary to the business office. This will allow the business office to update its billing system on a regular basis, allowing it to be scanned for any possible discrepancies. This should be done on a weekly basis without interruption—which means that if data cannot be provided digitally, it must be delivered in written format.

Once a month, usually on the first business day, a Medicare census should be sent from the business office billing system to all ancillary vendors. The vendors can then submit their accounts for their Medicare consolidated billing to the facility.

When these charges are received from ancillary vendors, they must be checked once again against the business office billing system Medicare census. Only once this double check is completed, should invoices be entered into the business office billing system, along with the PDPM classifications. After this, the UB-04 uniform billing forms can be issued.

Finally, prior to the transmission of the claims, the business office manager and the MDS coordinator or the director of nursing must certify with a final review that all the data is correct.

When a claim is paid, a copy of the remittance advice must be placed in the resident’s Medicare folder, and a copy kept for the SNF’s records.

One of the best ways to ensure compliance is to always deal with the data in manageable sizes. Keeping up a daily and weekly routine ensures that the amount of data does not become overwhelming, because the chance of errors being overlooked increases with the amount of data to be processed.