The role of Consolidated Billing as it relates to SNFs:
The consolidated billing requirement confers on the SNF the billing responsibility for the entire package of care that residents receive during a covered Part A SNF stay and PT, OT and ST received during a non-covered stay.

For more detailed information see: http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/SNFPPS/Downloads/historyQA.pdf

Even though non-therapy services may get billed by the individual providers under Part B, therapy services cannot. Quoting from page 2 of CMS’ Medlearn Matters Number SE0518: “The consolidated billing legislation is very emphatic that PT, OT and SLP services furnished to SNF residents are always subject to consolidated billing…” Said another way, any therapy service, regardless of provider or location (e.g. Hospital, mobile MBS truck, etc) is subject to the same rules and regulations.

Also, further down on page 2: “In a non-covered SNF stay, the beneficiary may be eligible for coverage of individual medical and other health services under Part B. Since the beneficiary still resides in a Medicare-certified institution (or part thereof) the therapy services are subject to the SNF consolidated billing provision. Under this provision, the claims for therapy services furnished during a non-covered SNF stay must be submitted to Medicare by the SNF itself. The SNF is responsible for reimbursing the provider. The SNF would bill its fiscal intermediary and be reimbursed under the Medicare fee schedule.”

For more detailed information please view the entire Medlearn Matters SEO518 Document.