"Under Arrangement" Agreements – Skilled Nursing Facility (SNF) Consolidated Billing

When an outside entity furnishes a service that is subject to Consolidated Billing (CB), there should be an arrangement in which the outside entity looks to the Skilled Nursing Facility (SNF) for the portions of its payment that are subject to CB, rather than to the Fiscal Intermediary, Carrier, A/B Medicare Administrative Contractor or beneficiary.

It is up to the SNF and the provider of the service to determine the specific details of the outside entity's payment by the SNF (in terms of how much the provider or supplier gets paid and when). These arrangements are a private matter between the SNF and the provider or supplier. Medicare does not have the authority to govern how the arrangements are made as long as the anti-kickback statutes are not violated.

The CB requirement confers on the SNF the billing responsibility for the entire package of care of Medicare-covered services that residents receive during a covered Part A SNF stay and physical therapy, occupational therapy, and speech language pathology services received during a non-covered stay in a Medicare certified bed. The SNF is responsible for notifying the outside providers or suppliers that they are treating a Part A SNF beneficiary for services that must be bundled back to the SNF (or for physical therapy, occupational therapy, and speech language pathology services received during a non-covered stay in a Medicare certified bed) and for setting up arrangements for these services. The SNF should inform each beneficiary and/or his or her representative(s) about CB requirements when he or she becomes a resident and each time he or she leaves the premises of the facility. The SNF is also required to ensure that any outside source from which it obtains a service meets the applicable standards for that service.

The outside provider or supplier must verify with the beneficiary, as well as the SNF, his or her Part A or Part B status prior to services being rendered. The provider or supplier shall refrain from submitting a separate Part B bill for consolidated services and will instead look to the SNF for payment. The provider or supplier should inform all beneficiaries in a covered Part A SNF stay of CB requirements in reference to the services they are receiving.

Medicare Learning Network Matters article MM 3592Adobe Portable Document Format provides further details on services provided "under arrangement."

Page Last Updated: Sunday, 28-Aug-2011 07:41:47 CDT