| Call for Action: POS 31 POS 32 - Grassroots Advocacy Outreach |
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by Michael Waserman, MD, CMD We have an immediate advocacy opportunity available for our members. Reach out to your Congressional representatives and ask them to contact CMS to reverse this mistake, lest we further discourage physicians from practicing in nursing homes. Based on a mistaken assumption, CMS has created a rule that leads to physician’s billing for services delivered to residents receiving skilled Part A care (POS 31) will be reimbursed at a lower rate than identical services delivered to custodial residents (POS 32). Two individuals in the same nursing home, even in the same room, receiving the same evaluation and management service from the same clinician, may generate different reimbursement solely because one is classified under Part A and the other is not. PALTmed has sent a letter to CMS that included the following: “I work for an independent doctor group, and I have seen many patients in both a SNF (POS 31) and NF (POS 32) and have had to bring the same equipment including my own stethoscope, laptop, and other supplies needed to deliver care. In many cases, the POS designation is not known to the practitioner providing the care as this is handled by the facility”. This real-world example underscores the core issue: practice expense remains the same whether the clinician sees a patient in POS 31 or POS 32, and the POS designation is handled administratively by the facility and may not even be known to the practitioner at the time of service. The patient may remain in the same bed, under the care of the same physician, with identical equipment, staff support, and documentation requirements. Yet payment changes solely based on certification status. The physician’s overhead and indirect costs do not change. To even determine this can actually significantly increase administrative burden as well and many electronic medical records are not well equipped to manage this in real time to ensure billing accuracy. We encourage our members to reach out immediately to their congressional representatives, asking them to contact CMS and have this mistaken rule rescinded. Link(s) for further reading: |