One finding providers should take note of is the three-day qualifying hospital stay required for skilled nursing facilities, according to William Malm, ND, RN, CMAS, senior data projects manager at Craneware.
"It is unclear what CMS will do with this information in the longer term. In 2011, CMS conducted a number of conference calls on the impact of observation at facilities and part of that discussion was on the three-day inpatient requirement for SNF admission for a covered stay," he said.
"CMS indicated that they were aware of the concern and would monitor it, and we now have CERTs stating this is an issue and that physicians are trying to admit to ensure covered stays for SNFs. Clearly the regulation is a challenge to patients and facilities. We would hope that CMS would review this and amend the process for SNF admission to include the most appropriate settings including observation."
As a result, providers should take a closer look at their records, says Malm.
"Providers should take a look at each record in which there was a discharge to a SNF and the transfer should be reviewed by at least two people—perhaps a coder and someone from internal audits, quality review or a physician advisor—to make sure it is compliant."