ASP-RCM Skilled nursing and long-term care billing.
SNF and long-term care billing across PDPM, MDS-driven case-mix, triple-check workflow, Medicaid pending tracking, and Medicare Advantage divergence.edicaid + commercial. Built for facility groups and standalone operators.
The SNF / Long-Term Care specialty stack.
For SNF / LTC administrators, CFOs, and HIM directors. Every item below runs in production today across the active client portfolio.
PDPM coding accuracy
MDS-driven case-mix maximized per CMS rules, with audit defensibility
Triple-check workflow
Pre-bill triple-check (clinical, financial, MDS) on every Medicare A bill
Medicaid pending discipline
Active pending tracking, follow-up cadence, escalation paths
MDS-driven case mix
Aligned with assessment cycle, not retroactively adjusted
Recoupment defense
Medicare audit response playbook with documented appeal sequence
Cross-payer reality
Medicare A + Medicare B + Medicaid + private pay tracked per resident
The per diem, drawn to scale
A skilled nursing per diem is assembled, not quoted.
There is no honest dashboard screenshot to put here, so we built the exhibit instead. Everything plotted below is the published PDPM classification structure and the published variable per diem schedule, not sample data and not a client. The long-form version of this exhibit lives in our PDPM revenue integrity guide.
Source: PDPM classification structure and the variable per diem schedule as published by CMS under the SNF prospective payment system. Rate year figures from the FY2026 SNF PPS final rule (CMS-1827-F), 90 FR 37310, published August 4, 2025, effective October 1, 2025.
The numbers that govern the rate
Six skilled nursing figures your CFO should be able to recite.
Every figure below is a current federal rule or the published classification structure. Nothing here is an estimate and nothing here is a client number.
PT, OT, SLP, nursing and NTA are case-mix adjusted off the assessment. Only the non-case-mix component covering room, board and administrative cost is immune to a coding error.
CMS PDPM classification structure, SNF PPS16 PT, 16 OT, 12 SLP, 25 nursing and 6 NTA. The five classifications become one five-character HIPPS code on the UB-04 claim line.
CMS PDPM classification structure, SNF PPSThe non-therapy ancillary component pays at three times its value for the first three days to front-load admission drug and supply cost, then 1.00 from day 4 through day 100.
CMS PDPM variable per diem scheduleTherapy holds 1.00 through day 20, then steps down 0.02 every seven days. A long stay dilutes the average per diem even when nothing about the coding changed.
CMS PDPM variable per diem scheduleSkilled care is covered up to 100 days per benefit period, with no resident coinsurance on days 1 to 20 and daily coinsurance from day 21. A new benefit period requires 60 consecutive days without skilled care.
Medicare SNF benefit period rulesA 3.3 percent market basket increase, plus a 0.6 percentage point forecast error adjustment, less a 0.7 percentage point productivity adjustment. The FY2026 labor-related share is 71.9 percent.
FY2026 SNF PPS final rule, 90 FR 37310Component anatomy
Six components, six different failure modes.
Treating PDPM as one thing is the most common analytical mistake in skilled nursing finance. The five case-mix components fail independently, for different reasons, and respond to different fixes. The only way to see that is to decompose the per diem and check each component against its own driver.
| Component | Groups | What sets the group | Variable per diem | Where it leaks |
|---|---|---|---|---|
| Physical therapyPT component, priced per day | 16 | Section GG function score plus the clinical category derived from the primary reason for the skilled stay. | Decays from day 21 | Function scored from a single observation rather than usual performance across the observation window. |
| Occupational therapyOT component, priced per day | 16 | Identical classification logic and the same function score as PT, which is why the two share one HIPPS character. | Decays from day 21 | Any PT error is automatically an OT error. One GG defect moves two components at once. |
| Speech-language pathologySLP component, priced per day | 12 | Acute neurologic clinical category, defined SLP comorbidities, cognitive impairment, swallowing disorder, mechanically altered diet. | Flat, no adjustment | Swallowing disorder and altered diet texture live in the chart but never reach the assessment. |
| NursingNursing component, priced per day | 25 | Extensive services, clinical conditions, the depression indicator, restorative nursing programs and the function score. | Flat, no adjustment | Restorative nursing delivered daily but never documented to the frequency threshold. |
| Non-therapy ancillaryNTA component, priced per day | 6 | A weighted comorbidity and extensive service point score, collapsed into six groups. | 3.00 on days 1 to 3 | Comorbidities present on the hospital record that never get coded onto the MDS inside the lookback. |
| Non-case-mixRoom, board, administrative | n/a | No resident characteristic changes it. It is the floor under every covered day. | Flat, no adjustment | Not exposed to coding error. This is the only component an assessment cannot understate. |
The 5-day PPS assessment carries an assessment reference date inside the first eight days of the covered stay, and the classification it produces prices the whole stay unless an Interim Payment Assessment replaces it. The IPA is optional under PDPM, which is exactly why it needs a written trigger list and has to be filed in both directions. A program that only ever finds reasons to raise the rate is not a revenue integrity program.
The boundary and the router
Benefit exhaust is a lane change, not a stop.
Two of the four places skilled nursing revenue leaks are not coding problems at all. They are boundary problems: who owns the bill during a covered Part A stay, and which lane the claim belongs in once the benefit runs out. Both are decided by a date and a rule, which makes both fully preventable before the claim is created.
| Consolidated billing | What sits there | Who bills it | Authority |
|---|---|---|---|
| Inside the bundleThe facility pays | All therapy, without exception. Routine drugs, biologicals and medical supplies. Most laboratory and diagnostic services. Routine radiology and portable diagnostics. Durable medical equipment used in the facility. Nursing services and the technical component of care. | The facility bills Medicare once, through the per diem. An outside supplier billing Part B for any of these is rejected and then invoices the facility. | 42 CFR 411.15(p) |
| Outside the bundleBilled separately | Physician professional services and the services of physician assistants, nurse practitioners, clinical nurse specialists, nurse-midwives, qualified psychologists and certified registered nurse anesthetists. Dialysis, related supplies and dialysis transport. Hospice care for the terminal condition. Certain chemotherapy items and administration. Radioisotope services and customized prosthetics. | The supplier or practitioner bills Medicare directly. These are the enumerated exceptions, and they are narrow. | 42 CFR 411.15(p)(2) |
| Cannot be furnished in a SNFHospital outpatient categories | Computed tomography, magnetic resonance imaging, cardiac catheterization, radiation therapy and angiography sit on the CMS major categories file describing hospital outpatient services a SNF cannot furnish. | Billed by the furnishing hospital outpatient department. The file is refreshed annually, so a screening rule set that was correct one federal fiscal year quietly goes wrong the next. | CMS annual file |
Two nuances trip up otherwise well-run buildings. Therapy is never excluded, not during a covered Part A stay and not for a resident in the facility outside one, where Part B therapy must still be billed by the facility. And the exclusion lists are annual files rather than permanent facts, so somebody has to own refreshing them. Source: 42 CFR 411.15(p), services excluded from coverage, including the enumerated exceptions at paragraph (p)(2).
Two systems, one hallway
Where Medicare Advantage diverges from fee-for-service.
A facility with a meaningful Medicare Advantage mix is running two reimbursement systems side by side, with the same clinicians. Fee-for-service days are won on assessment accuracy. Medicare Advantage days are won on authorization currency. The failure modes do not overlap, and a building that runs only one control loses money on the other side.
| Dimension | Fee-for-service, PDPM | Medicare Advantage |
|---|---|---|
| Rate structure | Six components summed, wage index adjusted on the labor share. The FY2026 labor-related share is 71.9 percent. | Negotiated: level-of-care tiers, a flat per diem, or a case rate. An MA plan is not required to pay a PDPM per diem. |
| What sets the rate | The 5-day MDS assessment, replaced only by an Interim Payment Assessment. | The contract, plus the level of care the plan authorizes. |
| Rate movement over the stay | PT and OT decay from day 21. NTA triples on days 1 to 3. | Whatever the contract says, commonly flat or tier stepped. |
| Length of stay control | Coverage criteria and the 100 day benefit period limit. | Prior authorization and concurrent review, on the plan clock. |
| Dominant denial pattern | Assessment defects, HIPPS mismatch, default rate days. CO-16 and N329. | No authorization on file, authorization expired mid-stay, missed concurrent review. CO-197 and CO-15. |
| Coverage criteria | Medicare coverage rules apply directly. | Must follow traditional Medicare criteria. Internal criteria only where Medicare criteria are not fully established, and they must be publicly accessible. |
| Where revenue is won | In the assessment window, inside the first eight days. | In the authorization queue, every day of the stay. |
Source for the coverage criteria row: Medicare Program; Contract Year 2024 Policy and Technical Changes to the Medicare Advantage Program (CMS-4201-F), 88 FR 22120, published April 12, 2023. MedPAC reports that more than half of eligible Medicare beneficiaries are enrolled in Medicare Advantage, which puts most skilled nursing admissions under plan-managed authorization.
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Skilled nursing billing FAQ
Questions SNF administrators and CFOs actually ask.
What are the five PDPM case-mix components?
Physical therapy, occupational therapy, speech-language pathology, nursing, and non-therapy ancillary. Each is classified into its own case-mix group and priced separately, then added to a sixth non-case-mix component that covers room, board, and administrative cost. PT has 16 groups, OT has 16, SLP has 12, nursing has 25, and NTA has 6. The five case-mix groups are what the five-character HIPPS code on the claim encodes, with PT and OT sharing the first character and the fifth character identifying the assessment used.
How does the PDPM variable per diem schedule work?
Two components change value as the stay ages. PT and OT are paid at an adjustment factor of 1.00 for days 1 through 20, then the factor steps down by 0.02 every seven days, reaching 0.76 for days 98 through 100. NTA runs the opposite way: an adjustment factor of 3.00 applies to days 1 through 3 to front-load the cost of admission medications and supplies, then drops to 1.00 for days 4 through 100. SLP, nursing, and the non-case-mix component carry no variable per diem adjustment and stay flat for the whole stay.
Why is the 5-day MDS assessment a revenue integrity control?
The 5-day PPS assessment sets the HIPPS code that prices every covered Part A day of the stay unless an Interim Payment Assessment replaces it. One assessment window, with an assessment reference date in the first eight days, determines up to 100 days of payment across five components at once. An understated Section GG function score, a missing swallowing or mechanically altered diet item, an uncoded depression screen, or a comorbidity that never made it out of the chart is not a one-day error. It repeats every day until discharge.
What is excluded from SNF consolidated billing?
During a covered Part A stay the SNF bundle covers nearly everything, and the exceptions are enumerated at 42 CFR 411.15(p)(2): physicians' professional services and the services of physician assistants, nurse practitioners, clinical nurse specialists, nurse-midwives, qualified psychologists, and certified registered nurse anesthetists, plus dialysis and related supplies and transport, erythropoietin for dialysis patients, hospice care for the terminal condition, ambulance for the initial admission and final discharge, certain chemotherapy items and their administration, radioisotope services, customized prosthetic devices, blood clotting factors, and rural health clinic and federally qualified health center services. CMS also publishes an annual major categories file covering hospital outpatient services that a SNF cannot furnish, including CT, MRI, cardiac catheterization, radiation therapy, and angiography. Therapy is never on the excluded list.
How does Part A versus Part B routing leak cash in a skilled nursing facility?
Medicare Part A covers up to 100 days of skilled care in a benefit period. When a resident exhausts those days, or drops below a skilled level of care while remaining in the building, the stay does not stop generating billable services. Therapy and certain ancillary services move to Part B. A facility that only runs a Part A billing workflow stops billing on the day the benefit runs out, and the resident days that follow become invisible. The exhaust date is knowable on the day of admission, so every resident should carry a benefit day count and a projected exhaust date from the first covered day.
How does Medicare Advantage diverge from fee-for-service PDPM?
An MA plan is not required to pay a PDPM per diem. Most pay a negotiated rate structure, often level-of-care tiers or a flat per diem, and they manage the stay with prior authorization and concurrent review rather than an assessment. That produces two different operating models in the same building: fee-for-service days are won on MDS accuracy, Medicare Advantage days are won on authorization currency. Since the contract year 2024 Medicare Advantage final rule at 88 FR 22120, MA plans must follow traditional Medicare coverage criteria and may use internal criteria only where Medicare criteria are not fully established, which makes the stated basis of a denial an auditable object rather than a matter of plan discretion.
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