APMA is aware that CMS and/or its Part B Contractors are recouping money from providers who submitted services that were performed for patients who were under a long-term nursing facility stay (Place of Service 32) using Place of Service 31 (Skilled Nursing Facility).
These recoupments appear to be happening to many different provider types and throughout the country. APMA staff, committees, and consultants are collecting information and strategizing an approach to CMS to discuss the fairness and appropriateness of these recoupments. Members who receive such a recoupment are encouraged to contact their administrative defense coverage carrier immediately.
APMA provides guidance on use of the 31 and 32 Places of Service at https://www.apma.org/rfcpos.
The OIG explains this recoupment at https://oig.hhs.gov/oas/reports/region4/42104084.asp.