I agree, but it is hard to persuade a facility not to place a resident being fed via a tube back on Medicare Part A when their FI has never denied any of their claims.

Just a comment.  Through my years of nursing in various venues, there have been repeated situations where the FI âinterpretationâ of a guideline resulted in denials etc and yet on appeal the facility was correct.  I would not change any of my thinking or functioning based on the âinterpretationâ of a representative of a fiscal intermediary unless they can give the source document.  As I have read the may e-mails r/t this topic I keep thinking that the phrase âcan be done by a lay person after a reasonable period of instruction and therefore loses its skilled connotation with timeâ is a concept of home health care.  After all in a home health situation they are not going to pay for daily care indefinitely as that would not be the reasonable venue.  The expectation would be that that patient would need to be admitted to a facility for that level of care. I keep wondering if someone has inadvertently tried to apply the same reasoning to SNF care which is inappropriate.  Of course, who knows what âtheyâ think at times.  I would proceed on the cautious side.  Who wants to be returning 100 days of reimbursement to the government? Ouch.

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