Q:
How does Consolidated Billing apply to dialysis services during a Skilled Nursing Facility (SNF) stay, and what is covered versus not covered?
A:
The consolidated billing requirement assigns the SNF the responsibility for billing the entire package of care provided during a covered Part A stay, as well as for physical, occupational, and speech therapy services during a non-covered stay. However, certain services are excluded from consolidated billing and are therefore separately payable. For Medicare beneficiaries in a covered Part A stay, these separately payable services include:
- Certain dialysis-related services, including covered ambulance transportation to obtain dialysis.
- Specific ambulance services, such as transportation to the SNF at admission, from the SNF at discharge (except in cases of transfer to another SNF), and roundtrip services required for offsite dialysis or certain intensive/emergency outpatient services.
- Erythropoietin for select dialysis patients.
Recent Changes to Dialysis-Covered Medications:
Effective in 2025, changes to the End-Stage Renal Disease (ESRD) Prospective Payment System (PPS) have impacted the coverage of certain dialysis-related medications for SNF residents. Previously, many dialysis medications were reimbursed separately under Medicare Part B, but new regulations now bundle additional medications into the ESRD PPS, creating potential compliance risks for SNFs. Facilities should review their billing practices and collaborate with dialysis providers to ensure proper reimbursement and avoid unexpected costs.
For more details, refer to CMS guidance on SNF Consolidated Billing and the ESRD PPS Consolidated Billing Updates (CR11506).
Written by:
Yetta Christian, RN, RAC-CT
Proactive LTC Consulting
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