2.0 Revisions
For Fiscal Year 2020
Under 10 United States Code (USC)
1079(i)(2), the amount to be paid to hospitals, SNFs, and other
institutional providers under TRICARE shall, by regulation, be established
“to the extent practicable in accordance with the same reimbursement
rules as apply to payments to providers of services of the same
type under Medicare.
On August 8,
2018, the Centers for Medicare and Medicaid Services (CMS) published
the Prospective Payment System (PPS) and Consolidated Billing for
Skilled Nursing Facilities (SNF) Final Rule for Fiscal Year (FY)
2019. In the rule, CMS documented its plan to replace the SNF PPS
RUG-IV classification system with a new case-mix classification
model called the Patient-Driven Payment Model (PDPM) beginning on
October 1, 2019.
5.0 Policy
5.1 Statutory
Background
In accordance with
32 CFR 199.4(b)(3)(xiv), covered services
in SNFs are the same as provided under Medicare under section 1861(h)
and (i) of the Social Security Act (42 USC 1395x(h) and (i)) and
42 CFR 409, Subparts C and D, except that the Medicare limitation
on the number of days of coverage under section 1812(a) and (b)
of the Social Security Act (42 USC 1395d(a) and (b)) and 42 CFR
409.61(b) shall not be applicable under TRICARE.
5.2 Applicability And Scope
All
TRICARE authorized SNFs must be authorized SNF providers under the
Medicare program, and meet the requirements of Title 18 of the Social
Security Act, sections 1819 (a), (b), (c), and (d) (42 United States
Code (USC) 1395 i-3(a) - (d)), or subsequent regulations.
5.2.1 If a pediatric SNF is certified
by Medicaid, it will be considered to meet the Medicare certification
requirement to become an authorized provider under TRICARE. The
contractor shall send a cover letter and Participation agreement,
which is provided at
Addendum A, to any SNFs that are not authorized
by Medicare, but would qualify as a TRICARE-approved pediatric SNF.
The contractor shall be responsible for verification that the SNF
is Medicare-certified (or Medicaid-certified) and has entered into
a Participation Agreement with TRICARE.
5.2.2 VA facilities are required to be Medicare
approved or they are required to be Joint Commission accredited
to have deemed status under Medicare or TRICARE. Unless required
in their Memorandum of Understanding (MOU) or Participation Agreement,
Department of Veterans Affairs (VA) facilities may not be subject
to SNF PPS (see
paragraph 6.2).
5.3 SNF Admission Criteria
5.3.1 TRICARE follows Medicare requirements for
admission to a SNF and any exception policy per Medicare Benefit
Policy Manual, Chapter 8. For a SNF admission to be covered under
TRICARE, the beneficiary must both have a qualifying hospital stay
of three consecutive days or more, not including the hospital discharge
day, and the beneficiary must enter the SNF within 30 days of discharge
from the hospital.
5.3.2 TRICARE
is adopting Medicare’s Interrupted Stay Policy.
• TRICARE
will adopt the Medicare definition of an interrupted stay as one
in where a patient is discharged from a SNF and subsequently readmitted
to the same SNF during the interruption window. The interruption
window is a three-day period that begins on the first non-covered
day following a SNF stay and ends at 11:59pm on the third consecutive
non-covered day. If both conditions are met, the subsequent stay
is considered a continuation of the previous “interrupted” stay
for the purposes of both the variable per diem schedule and the
assessment schedule.
• If the patient is readmitted to the same
SNF outside the interruption window, or any instance when the patient
is admitted to a different SNF (regardless of the length of time between
stays), then the Interrupted Stay Policy does not apply, and the
subsequent stay is considered a new stay. In such cases, the variable
per diem schedule resets to Day 1 payment rates, and the assessment
schedule also resets to Day 1, necessitating a new five-day assessment
required.
5.3.3 When TRICARE is the primary payer,
the contractor shall determine whether the beneficiary meets the
criteria for coverage. The contractor shall use the information
in block 35 and 36 of CMS 1450 UB-04 to make the admission determination.
If block 36 of CMS 1450 UB-04 is blank, the SNF claim will be denied
unless the patient was involuntarily disenrolled from a Medicare
+ Choice plan. The contractor shall calculate the Length-Of-Stay
(LOS) based on the SNF actual admission date provided on the CMS
1450 UB-04 claim form. Any adverse TRICARE determinations involving
medical necessity issues will be appealable to TRICARE whenever
TRICARE is the primary payer. However, a denial based on the factual
dispute (not the medical necessity) of SNF benefit for failure to
meet the three-day prior hospitalization or “within 30 days” requirement
is not appealable. Any factual disputes surrounding the three day
prior hospitalization or “within 30 days” requirement can be submitted
to the TRICARE contractor for an administrative review.
5.4 SNF MDS Assessments
5.4.1 The Medicare-certified SNF must assess
the beneficiary using the Minimum Data Set (MDS) assessment form
for the SNF PPS rate to be applied.
5.4.2 Under the PDPM, SNF residents will
be assessed using MDS by SNFs at day 5 and at discharge (see PDPM
FAQ on Medicare Website at
https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/SNFPPS/PDPM.html).
The interim payment assessment (IPA) is optional and will be completed
when providers determine that the patient has undergone a clinical
change that would require a new PPS assessment. SNFs are not required
to assess a resident upon readmission, unless there has been a significant
change in the resident’s condition. If a significant change is found,
the facility will follow Medicare policy for additional reviews.
5.4.3 SNFs are not required to automatically
transmit MDS assessment data to the TRICARE contractors. However,
the TRICARE contractor, at its discretion, may collect the MDS assessment
data and documentation for claim adjudication or audit and tracking
purposes at any time from SNFs when TRICARE is the primary payer.
5.4.4 For TRICARE dual eligible beneficiaries,
during the first 100 days of an inpatient SNF stay, TRICARE will
function as a secondary payer to Medicare under the SNF PPS in which
case there is no need for TRICARE to collect the MDS assessment
data. At any time when TRICARE is primary payer, the MDS assessment
data shall be collected by TRICARE for audit and tracking purposes.
5.4.5 SNF staff will follow Medicare policy
and use the MDS grouper which uses MDS data to classify patients
into PDPM groups. The grouper will then generate an appropriate
four-digit PDPM code. To supplement the four-digit codes, the SNF
will add a one-digit assessment indicator using codes determined
by Medicare to indicate the reason for the MDS assessment before
submitting the claim for payment. The five digits make up the Health
Insurance Prospective Payment System (HIPPS) code. The SNF will
enter the HIPPS code on the CMS 1450 UB-04 claim form in the Healthcare
Common Procedure Coding System (HCPCS) code field that corresponds
with the Revenue Code 022. The components of this code are used
within the pricer (see
paragraph 5.5.2) to determine payment. SNFs will
code the fifth digit using Medicare MDS assessment codes to indicate
either initial, PPS discharge, or Interim Payment Assessments (IPA).
5.4.6 For untimely assessments, if the SNF
does an off-schedule assessment, or in some cases no patient assessment
at all, the SNF will submit the claim with a default rate code ZZZZZ
and the SNF will be reimbursed at the lowest PDPM pricing.
5.5 SNF PPS Payment Method
5.5.1 TRICARE reimbursement will follow
Medicare’s SNF PPS methodology and assessment schedule for all TRICARE
patients (including those Active Duty Service Members (ADSMs) using Supplemental
Care benefits, Transitional Assistance Management Program (TAMP)
beneficiaries, and Continued Health Care Benefit Program (CHCBP)
beneficiaries) admitted at Medicare-certified SNFs (or Medicaid-certified
pediatric SNFs), with specific exceptions as noted later in this
section. SNF PPS will apply to TRICARE beneficiaries who satisfy
the qualifying coverage requirements of the TRICARE SNF benefit.
5.5.2 The PPS
payment rates will cover all costs of furnishing covered SNF services
(routine, ancillary, and capital-related costs). For items that
Medicare pays outside the SNF PPS consolidated billing rules (e.g.,
professional services of physicians, chemotherapy), TRICARE will
also pay outside the SNF PPS rate utilizing the appropriate TRICARE
reimbursement system. The CB provisions of the SNF PPS are provided
at
https://www.cms.gov/Medicare/Billing/SNFConsolidatedBilling/index.html.
5.5.3 Claims will be paid at 100% of the
PPS rate.
5.5.4 Claims processors shall regularly
monitor and download the latest Medicare SNF PPS Pricer software
from the Medicare website:
https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PCPricer/SNF.html and
replace the existing pricer with the updated pricer within 10 calendar days
of download. Claims processors must maintain the last version of
the pricer software for each prior fiscal year and the most recent
quarterly release of the current fiscal year.
5.5.5 The pricer will provide the contractor
the calculated rate for a one day stay for the claim’s dates of
service. Contractors shall multiply the PPS amount calculated by
the pricer by the number of revenue 022-line units on the claim
to come up with the complete amount for that HIPPS claim line.
5.5.6 Claims processors will not need to
split claims when a SNF admission crosses fiscal year dates. Providers
are to prepare separate bills for services prior to and on or after
October 1 as the SNF PPS rate is updated for each fiscal year.
5.6 Additional SNF Data
5.6.2 The SNF-PPS base rates will be posted
for each PDPM category annually. Contractors shall not wait for
issuance of these routine changes for implementation, because the
SNF rate, wage index, and these updates are built into the SNF PPS
pricer.
5.7 Miscellaneous
Policy
5.7.1 Medicare
is the primary payer for all dual eligibles during the first 100
days of SNF care per benefit period. For all care after 100 days,
TRICARE becomes the primary payer for Medicare-eligible beneficiaries
who have no other health insurance. TRICARE is also the primary
payer for non-Medicare-eligible TRICARE beneficiaries who do not
have other health insurance and who meet the TRICARE SNF coverage
requirements. In both situations, TRICARE’s coordination of benefit
rules will determine TRICARE’s status as primary payer.
5.7.3 With regard to payment for the lower
PDPM classification groups, TRICARE will follow the SNF level of
care criteria as provided in the Medicare Benefit Policy Manual,
Chapter 8. If individual reviews are required by Medicare, the contractor
will be responsible to conduct the review for TRICARE primary-payer
patients to ensure that they meet criteria for skilled services
and the need for skilled services as defined in 42 CFR 409.32, Subpart
D. In determining “medical necessity”, the contractor shall use
generally acceptable criteria such as InterQual.
5.7.4 At their own discretion, the contractors
shall conduct any data analysis to identify aberrant PPS providers
or those providers who might inappropriately place TRICARE beneficiaries
in a high PDPM category.
5.7.5 Refer
to the TRICARE Systems Manual (TSM),
Chapter 2 for
the SNF PPS related revenue and edit codes.
5.7.6 The Waiver of Liability provisions in the
TRICARE Policy Manual (TPM),
Chapter 1, Section 4.1 apply to SNF cases.
5.7.7 TRICARE will allow those hospital-based
SNFs with medical education costs to request reimbursement for those
expenses. Only medical education costs that are allowed under the
Medicare SNF PPS will be considered for reimbursement. These education
costs will be separately invoiced by hospital-based SNFs on an annual
basis as part of the reimbursement process for hospitals (see
Chapter 6, Section 8). Hospitals with SNF
medical education costs will include appropriate lines from the
cost report and the ratio of TRICARE days/total facility days as
described in
Chapter 6, Section 8. The product will equal
the portion that TRICARE will pay. TRICARE days do not include any
days determined to be not medically necessary, and days included
on claims for which TRICARE made no payment because Other Health
Insurance (OHI) or Medicare paid the full TRICARE allowable amount.
The hospital’s reimbursement requests will be sent on a voucher
to the DHA Finance Office for reimbursement as a pass-through cost.
5.7.8 The need for enteral feedings may not,
alone, provide a sufficient basis for obtaining TRICARE coverage
of care provided in a SNF. Enteral feedings are not services that
can be provided only at a SNF level of care. The SNF extended care
benefit covers relatively short-term care as a continuation of treatment
begun in the hospital. The initiation of enteral feedings or provision
of skilled care needed to manage documented difficulties or complications
with the feedings may be considered skilled services that qualify
for SNF care. However, once a beneficiary is stabilized for routine
enteral feedings, a lower level of care may be more appropriate,
such as a home care setting or assisted living facility, with non-licensed
family members or facility staff trained to provide feedings and
only intermittent involvement of nursing personnel needed to provide
oversight. The appropriate level of care is subject to medical necessity
review.
5.8 Preauthorization
SNF care received in the United
States (U.S.) and U.S. territories will require preauthorization
if TRICARE is the primary payer. The TDEFIC contractor shall preauthorize
care beginning on day 101, when TRICARE becomes primary payer for
dual eligible beneficiaries without other health insurance. TRICARE
contractors, at their discretion, shall conduct concurrent or retrospective
review for TRICARE Select or TRICARE For Life (TFL) patients when
TRICARE is the primary payer. There will be no review when TRICARE
is the secondary payer. The existing referral and authorization
procedures for Prime beneficiaries will remain unaffected.
6.0 Exclusions
6.1 CAH swing beds are excluded from the SNF
PPS methodology.
6.2 VA facilities are excluded from the
SNF PPS methodology unless there is a SNF Participation Agreement
or MOU in place establishing that they will be reimbursed with the
SNF PPS methodology.
6.3 Children under age 10 at the time
of admission to a SNF that are not assessed using the MDS are exempt
from the SNF PPS methodology. The TRICARE contractor shall negotiate
these reimbursement rates utilizing their best business practices.
6.4 When no TRICARE inpatient SNF PPS
program payment is possible, otherwise covered medically necessary
services and supplies may be allowed under TRICARE’s outpatient
benefit. However, nursing care provided in a SNF setting is not
billable under the TRICARE outpatient benefit. For TRICARE dual
eligible beneficiaries, Medicare is primary payer for all Medicare
Part B services; therefore, the SNF will need to bill CMS for these
outpatient SNF services, rather than first submitting a claim to
TRICARE. (See
Chapter 4, Section 4.)