CMS Issues Update on the Use of Physician Assistants to Perform SNF Level of Care Certifications and Recertifications

Change Request (CR) 7701 implements Section 3108 of the Affordable Care Act. This section adds physician assistants to the list of practitioners who can perform SNF level of care certifications and recertifications. Performing this function is a requirement for Medicare coverage of Skilled Nursing Facilities (SNF) services under Part A.

The provider types affected are SNFs and swing-bed hospitals that bill Medicare Contractors (Fiscal Intermediaries (FIs) or A/B Medicare Administrative Contractors (A/B MACs)) for Providing Part A SNF services to Medicare beneficiaries are affected.  CR 7701 directs Medicare Contractors to recognize that, effective with services furnished on or after January 1, 2011, physician assistants can perform the required initial certification and periodic recertifications of a beneficiary’s need for a SNF level of care.

Contractors will reopen and reprocess any claims brought to their attention for Part A SNF services that were mistakenly denied (prior to this update) based on having a physician assistant complete the required SNF level of care certification or recertification. However, contractors will not search claims history to identify these claims.

The official instruction, CR 7701, was issued to fiscal intermediaries and Medicare Administrative Contractors regarding this change via two transmittals. The first modifies the 'Medicare General Information,' Eligibility and Entitlement manual and it may be viewed here on the Centers for Medicare & Medicaid Services (CMS) website.  The second updates the 'Medicare Benefit Policy' manual, which is available here.