Should I complete an Interim Payment Assessment (IPA) if a Medicare Part A resident becomes COVID-positive during a skilled therapy stay?
Whether or not to complete an IPA should be a case-by-case decision. Because the IPA is an optional assessment, SNF staff determine if and when an IPA will be completed.
As the name implies, the purpose of the IPA is to establish a payment rate or billing code for billing Medicare Part A. Consider the current daily rate and if the projected IPA rate would increase reimbursement. If the changes will result in an increase, the IPA should be scheduled — allowing adequate time to complete supporting documentation, section GG interim performance and MDS scripted interviews.
Do not set the IPA earlier than the day the team determined it was warranted, as dashes on the assessment could substantially affect payment because the team wasn’t allotted time to collect information for all sections.
It is important to also monitor the skilled level of care. To continue to bill Medicare for this skilled stay, the resident must continue receiving daily skilled care (per Chapter 8 of Medicare Benefit Policy Manual). That requires seven day-a-week nursing coverage or at least five days of therapy coverage.
If therapy reduces services below this threshold because of a COVID-19 diagnosis, the resident would no longer meet the skilled level of care criteria. The resident may be receiving skilled nursing services, but the Centers for Medicare & Medicaid Services has clarified that a “COVID-19 diagnosis would not in and of itself automatically serve to qualify a beneficiary for coverage under the Medicare Part A SNF benefit” (per COVID-19 FAQ on Medicare FFS Billing). The focus must be on the skilled services being provided on a daily basis.
