Are Visits to an SNF by an RHC Provider an RHC Visit?

Bill Finerfrock, Executive Director

Are Visits to an SNF by an RHC Provider an RHC visit?

Recently, an NARHC News listserve participant posted a question/concern regarding a comment she heard during a webinar conducted by the Medicare MAC – Noridian. The commenter stated that the representative from Noridian stated that visits to a SNF by an RHC provider were not RHC visits and should be billed on the 1500 claim form and not billed on the UB-04. If correct, this would constitute a significant change in CMS policy (as well as the Medicare statute).

NARHC contacted the Noridian representative to whom the above comments were attributed and sought clarification. Here is what we asked and the responses to our inquiry:

NARHC News Commenter stated:

“In that Webinar she stated that Providers that go to a SNF to render services are outside of the rural health clinic and should be billed as a non-RHC encounter and on a 1500 form. I asked again during the Q&A and she reiterated this as fact according to the IOM.”

In response, the Noridian representative said that she was specifically referencing a situation in which the RHC provider was NOT being compensated by the RHC during the time the visit occurred. Specifically:

If the RHC physician is not compensated for services provided in the SNF the physician may bill on the 1500 form.

We also sought additional clarification by writing: First, did you say that SNF visits were not billable as RHC visits on the UB-04 claim form and if so, why?

No RHC visits can take place in a SNF. I was listing non-RHC services which the IOM states that a NON-RHC service is a service where the RHC does not compensate a physician service (RHC Part One slide 64).

The Noridian answer is correct but it is important that you pick up the specific context. “… the RHC physician is not compensated for services provided in the SNF” by the RHC.

SNF visits by RHC providers are RHC visits and billable as an RHC encounter on the UB-04 Claim form. We hope this helps to clear up any misunderstanding and we appreciate that Noridian staff responded to our inquiry in an effort to ensure that there was no lingering confusion.

Bill Finerfrock
202-544-1880
bf@narhc.org