SNF Billing Changes for 2022
Skilled nursing facility (SNF) billers will need to be prepared for multiple changes affecting billing and payment for services provided in 2022.
Medicare Part B physician’s fee schedule rates have been finalized for 2022. Billing staff should verify software has been correctly set up to reflect these changes prior to billing January services. A complimentary rate calculator for calendar year (CY) 2022 is available on our website.
In CY 2020, Medicare began the requirement to bill with modifiers CQ and CO to indicate services performed in whole or in part by a physical therapy assistant (PTA) or occupational therapy assistant (OTA). The 2022 Medicare Physician Fee Schedule final rule provided further specifics on when these modifiers are required for billing purposes. The de minimis threshold requirements and specific billing examples can be found on the CMS website.
Effective with service dates on or after January 1, 2022, services performed in whole or in part by a PTA or OTA will pay at a 15 percent reduction to the Medicare portion (80 percent) of the fee schedule. Since the patient portion (20 percent) is not reduced, this equates to a 12 percent reduction overall. When services are impacted by both the multiple procedure payment reduction (MPPR) and the PTA/OTA reduction, the MPPR reduction is calculated first, then the PTA/OTA reduction, and finally sequestration when applicable. Most billing systems require additional setup to correctly apply these reductions.
The Part B KX modifier threshold (previously referred to as the therapy cap) increased to $2,150 for CY 2022. As in prior years, the threshold calculation is combined for both physical therapy and speech-language pathology (SLP) services, while occupational therapy services are calculated separately.
The SNF Medicare Part A coinsurance rate for 2022 is $194.50.
On January 16, 2022, the U.S. Department of Health & Human Services renewed the public health emergency for another 90 days. The 1135 health waivers are still in place during this time, which waive the three-day qualifying hospital stay requirement and in specific situations provide a one-time renewal of the Part A SNF benefit period. Information on the effect of the waivers, including qualification requirements and billing specifications, can be found in CMS MLN Matters Number SE20011, last revised September 8, 2021.
The 2 percent sequestration continues to be on hold through March 31, 2022, service dates. Beginning with April 1, 2022, service dates, a 1 percent sequestration will be withheld from the Medicare portion of payments. Effective with July 1, 2022, service dates, the 2 percent sequestration will be back in place. Billing systems will need to be set up to correctly apply these reductions to the correct service periods.
If you have questions about these changes, reach out to your BKD Trusted Advisor™ or submit the Contact Us form below.