This may be after-the-fact, but I remember breezing through some posts this week discussing the billing of 47 residents if you had 47 Medicare certified beds, and the FI didn't care where they were at.  
We are a distinct part, and I had never heard of this.  Thought I'd mention I was just reading in an older bulletin from AAHSA (August 4, 2003) discussing some areas of the final update for PPS.  One was on distinct part definitions.  It states that "CMS maintains the restriction in designating beds in a distinct part. CMS insists that beds in a distinct part be identified as an entire or contiguous wing, floor or building.  CMS specifically indicates that beds may not be scattered and that prior approval of a distinct part is required with no exceptions." 
You can view the report on AAHSA's web site.

I apologize if this issue was already resolved.  Thanks!


Linda Budde, RN
Reimbursements
Friendly Acres, Inc.


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