Arizona Rural Health Clinic Designation Manual - Arizona Center for ...

D. Frequently Asked Questions (con’t)
Q: Can our doctors, during RHC time, treat patients at a residential care facility and assisted living
care facility and be reimbursed Can our doctors do house calls and get paid
A: If the medical provider treats patients in a Skilled Nursing Facility (SNF) (100-day Part A bed)
in a nursing home, those services are billed to Part B, and cannot be included in Part A encounters
like other nursing home visits. Only those patients in the 100-day Part A bed have to be billed to
Part B. The rest of the nursing home visits are billed thru Part A as a regular RHC encounter, at the
RHC encounter rate. Any time Part B is billed for a service provided, you must also “carve out”
the associated cost of that service from the RHC cost report. Certainly, medical providers can still
provide treatment for patients in a residential care facility, if that is the patient’s place of residence,
and it is handled the same as a house call or home visit billed to Part A as an encounter. There are
three places of service where the medical provider can bill as an RHC encounter. They are:
1) In the Rural Health Clinic
2) In a nursing home (not a 100-day Part A stay) or other medical facility
3) In the patient’s place of residence or at the scene of an accident.
Q: Can our clinic at a satellite location offer health services outside of the RHC
A: No. The Medicare program makes payments to the RHC for covered RHC services when provided
to a patient at the clinic, skilled nursing facility or other medical facility, the patient’s place
of residence, or elsewhere (i.e., at the scene of an accident).
Q: How would the organizational relationships between a RHC and Critical Access Hospital
(CAH) operate
A: The RHC and CAH programs are two separate programs and have different participation criteria.
If the facilities follow the individual criteria for their respective programs, then the two
programs could co-exist. A CAH could be the owner of a certified RHC and operate the RHC
as either a provider-based or independent clinic. From an economic standpoint, the CAH would
be well advised to compare the payments for the clinic if operated as an RHC or as an outpatient
department of the CAH. CAH outpatient payments are typically better than outpatient payments
for traditional hospitals.
Q: We are an RHC all day. For Medicare patients regarding CPT coding, can we use minutes vs.
time spent with the patient
A: Time cannot be a factor when deciding to code up or down. Coding depends on history, examination,
and the medical decision needed. For example, one patient may take 30 minutes but have
nothing wrong with them while another patient may be seen for only a few minutes before they
are sent to the emergency room. Coding depends on the medical decision-making, not the amount
of time.
Q: If you make rounds at the nursing home and you see a patient who is on hospice, can you bill
it as an RHC visit
A: If the hospice patient receives services from you that are unrelated to the patient’s terminal condition,
then you can then bill the visit to the RHC. However, if you are adjusting pain medications
or providing supportive care, then you must bill hospice.
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