Update on Comparative Billing Reports: Skilled Nursing Facility Billing Practices

On August 31, the Centers for Medicare and Medicaid Services (CMS) released a national provider Comparative Billing Report (CBR) addressing skilled nursing facility (SNF) billing practices. The CBRs are being produced by SafeGuard Services under contract with CMS and contain data-driven tables and graphs with an explanation of findings that compare an individual provider's billing and payment patterns to those of their peers located in the state and across the nation.

These reports are not available to anyone except the providers who receive them. To ensure privacy, CMS presents only summary billing information. No patient or case-specific data is included. These reports are intended to serve as a tool that helps providers better understand applicable Medicare billing rules and improve the level of care they furnish to their Medicare patients.

Responding to questions from the American Health Care Association (AHCA), SafeGuard recently provided additional information about the CBRs.

  • How many SNFs received the comparative billing reports?  Five thousand SNFs received the reports.
  • How were SNFs selected to receive the comparative billing reports?  CMS evaluated its data and provided a list of 5,000 SNFs that were identified as having the highest volume of Medicare Part A services paid.
  • What specifically does the report focus on?  The report is based on Medicare final claims data from Jan. 1, 2011, through Dec. 31, 2011.  The following RUGs are included in the analysis:

Rehabilitation Plus Extensive Services: RUX, RUL, RVX, RVL, RHX, RHL, RMX, RML, & RLX; and

Rehabilitation: RUC, RUB, RUA, RVC, RVB, RVA, RHC, RHB, RHA, RMC, RMB, RMA, RLB, & RLA.

The utilization measures analyzed in the report are:

  • the percentage of beneficiaries billed by therapy level grouping among the rehabilitation plus extensive services category for your SNF;
  • the percentage of beneficiaries billed by therapy level grouping among the rehabilitation services category for your SNF, and
  • the percentage of beneficiaries billed for ultra-high RUG codes among all therapy RUG codes for your SNF.

These measures will be statistically compared to the average of your CMS Region and national peers.

  • Does Safeguard have a sample of the comparative billing report?  Click here to see a sample of the SNF comparative billing report.  
  • Some SNFs are alerting AHCA that the comparative billing report contains inaccurate data – what should SNFs do in that instance?  Facilities should call the number identified below (530.896.7080) to report inaccurate information; but for a quicker response, click here and fill out the inquiry form.  On that form, facilities can also alert Safeguard to the best time for you to receive a return call.
  • Is CMS, Center for Program Integrity (CPI) managing this effort?  This effort is not initiated or managed by CPI.  Instead, it is coming from CMS, Office of Financial Management, Provider Compliance Group (George Mills, Director).
  • What are CMS’ plans for follow-up on these comparative billing reports?  We have been told that CMS has no plans to follow-up with the SNFs who were sent the comparative billing reports at this time.
  • Will CMS be sharing these comparative billing reports with other federal agencies?  We have been told there are no plans to share this information with other federal agencies at this time.
  • Additional information on SNF Comparative Billing Reports can be accessed here or by calling the SafeGuard Services’ Provider Help Desk, CBR Support Team at 530.896.7080.