- CMS should analyze the potential impacts of counting time spent as an outpatient toward the 3-night requirement for skilled nursing facility (SNF) services so that beneficiaries receiving similar hospital care have similar access to these services.
- CMS should implement the statutory mandate requiring surety bonds for home health agencies that enroll in Medicare and consider implementing the requirement for other providers.
- CMS should continue to ensure that medical device-specific information is included on claim forms and require hospitals to use certain condition codes for reporting device replacement procedures.
- CMS should seek statutory authority to establish additional remedies for hospices with poor performance.
- CMS should seek legislative authority to comprehensively reform the hospital wage index system
- CMS should reevaluate the inpatient rehabilitation facility (IRF) payment system, which could include seeking legislative authority to make any changes necessary to more closely align IRF payment rates and costs.
- CMS should periodically review claims for replacement positive airway pressure device supplies and take remedial action for suppliers that consistently bill improperly.
- CMS should consider seeking legislative authority to implement least costly alternative policies for Part B drugs under appropriate circumstances.
Following the release of this document, CMS published a new fact sheet urging SNFs to “correctly understand the 3-day rule to avoid inappropriately submitting claims that do not meet the 3-day rule.”