I am sure everyone agrees that not only is providing healthcare complicated, but so are all the administrative aspects of healthcare. And as a result, we all count on others to help guide us. Occasionally, that advice could, if not interpreted perfectly, lead one astray.
So, as I have done in the past, I am writing this article to offer some clarifications on something someone else said. And interestingly, it’s a topic I have discussed in the past, but it is worth repeating.
During last week’s Talk Ten Tuesdays, Chris Geiger reported that she was asked about whether an inpatient who was waiting transfer to a skilled nursing facility (SNF) could be discharged, then re-registered as outpatient. I did learn from her that there is a Z code, Z75.1, which indicates a person awaiting admission to an adequate facility elsewhere.
I am a strong advocate of Z codes, and urge their use to capture the social factors that our patients face, but had no idea this code for the patient awaiting transfer existed! She also discussed what (healthcare attorney) David Glaser recently discussed, about the ability to certify inpatient days for patients awaiting SNF transfer and bill those days as medically necessary to Medicare.
And Tiffany Ferguson, in her segment, went even further, explaining that a patient cannot be discharged from inpatient status and then registered as outpatient to await SNF transfer. A patient is discharged when they either discharge, die, or transfer to another facility. Now, the one exception, in which a patient can be discharged and re-registered without leaving their bed, is when an inpatient in a rural or critical access hospital is admitted to swing-bed status. That’s it.
But there is an important distinction here.
We often refer to nursing homes as SNFs. But that’s not technically correct. Most nursing facilities provide varying levels of care. There are skilled beds that are approved to provide skilled care, paid for under Part A or by Medicare Advantage (MA) plans or other insurance, and then they have those beds for people who consider the facility their home, sometimes called long-term care.
They are still eligible to get services under Part B or other insurance, but their room and board is not paid for by insurance. So, a nursing facility can be both a SNF and a long-term care facility.
So, back to the original question about the patient awaiting transfer to a SNF. You have to determine if there is a need for skilled nursing care, or is it a need for long-term custodial care? Many patients who discharge from hospitals have no skilled needs, but can no longer manage at home, and our intrepid case managers work very hard to find placement. And while that search goes on, if their need for hospital care has ended, they will remain as inpatient – but those days cannot be certified, as can days awaiting skilled care in a nursing facility.
How do we differentiate between these two options when billing that inpatient admission? Well, Z75.1 applies to both circumstances, so while it should be used as a diagnosis, it won’t separate days that can be certified as necessary from custodial days. What will differentiate them is the proper use of occurrence span codes on the claim. Span code 74 indicates dates during an inpatient stay on which care is provided while the patient awaits transfer for long-term care, whereas span code 75 would be used for days that the patient is waiting for transfer for skilled care.
So, as everyone is faced with increased difficulty finding post-acute care for patients, be sure your documentation uses the right terminology to indicate the type of post-acute care they need, so the claim can be prepared correctly for all those cost, quality, and efficiency measures that come from that one form.
