CMS has released a Medicare Learning Network (MLN) Matters article titled “Physician Delegation of Tasks in Skilled Nursing Facilities (SNFs) and Nursing Facilities (NFs)”. The information affects physicians, non-physician practitioners (NPPs) and providers who bill for services related to beneficiaries in SNFs and NFs.
CMS is clarifying the regulatory differences concerning physician delegation of tasks in SNFs and NFs. The distinction in policies between these two settings (SNFs and NFs) is based in statute and regulation. Improper application of these regulations may affect a facility’s compliance and payment to providers.
According to the MLN Matters article, the key to accurate application is to identify:
- In which setting, SNF or NF, the physician services are being provided;
- Whether the task must be performed personally by the physician; and
- Whether or not the NPP is employed by the facility.
The “setting” is determined by whether the visit to a resident in a certified bed is to a resident whose care is paid for by Medicare Part A in a SNF or to a resident whose care is paid for by Medicaid in a NF.