Karen Oskey--WI

Timely filing- Recovery auditors can go back three years; hospitals should not be limited to 1 year from date of service for accepting a denial and being paid full part B. This inequity will lead to the recovery auditors delaying denials until past the timely filing deadline. Perhaps suggest that hospitals be allowed 120 days from date of denial to either appeal denial or accept findings and file Part B to match the redetermination time frame. SNF qualification- if a patient had a three day qualifying stay and transferred to a SNF for Part A services, and that hospital stay is subsequently denied, it is unclear where the financial liability lies for the SNF visit. Ask that CMS clarifies that and suggest that the patient, hospital and SNF be held harmless and not made to repay any money already paid to the SNF for the care. Patient financial responsibility- Since part A and part B financial obligations differ, a part A denial that is rebilled as part B can increase patient liability if it was a surgery or procedure admission, and of course the cost of self-administered medications now shifts to the patient. And with the ability to self-audit, there will be more conversions from part A to part B. But waiving patient financial liability and shifting it to the hospital will result in a reduction of 20% in the approved amount which is not financially sound for the hospital. I am going to suggest that in these cases the patient be held harmless. To balance the added burden, the part B payment to the hospital from CMS would be 100% of the approved amount and that hospitals must waive any costs for self-administered medications and any other patient-incurred costs.