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SNF / LONG-TERM CARE BILLING SERVICES

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.

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Where the depth is

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.

01

PDPM coding accuracy

MDS-driven case-mix maximized per CMS rules, with audit defensibility

02

Triple-check workflow

Pre-bill triple-check (clinical, financial, MDS) on every Medicare A bill

03

Medicaid pending discipline

Active pending tracking, follow-up cadence, escalation paths

04

MDS-driven case mix

Aligned with assessment cycle, not retroactively adjusted

05

Recoupment defense

Medicare audit response playbook with documented appeal sequence

06

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.

PDPM component stack and variable per diem schedule PDPM VARIABLE PER DIEM ADJUSTMENT FACTORS, BY DAY OF STAY PT AND OT: 1.00 THROUGH DAY 20, THEN DOWN 0.02 EVERY 7 DAYS NTA: 3.00 ON DAYS 1 TO 3, THEN 1.00 TO DAY 100 1.000.900.800.70 3.002.001.00 day 12060100 day 150100 decay begins day 21 0.76 on days 98 to 100 The triple is 3 days of a 100 day stay.A short stay carries the whole front load,which is why length of stay has to be acovariate in any per diem trend. SLP, nursing and the non-case-mix component carry no variable per diem adjustment. They pay at 1.00 for every covered day of the stay. THE SIX COMPONENTS OF ONE COVERED PART A DAY, SIZED BY CASE-MIX GROUP COUNT Physical therapy Occupational therapy Speech-language pathology Nursing Non-therapy ancillary Non-case-mix 161612256 n/a DECAYS 0.02 EVERY 7 DAYS FROM DAY 21 SAME CLASSIFICATION AS PT, SAME DECAY FLAT, NO ADJUSTMENT FLAT, NO ADJUSTMENT 3.00X ON DAYS 1 TO 3 FLAT. NO ASSESSMENT MOVES IT Five of the six components respond to what the 5-day MDS says about the resident. One does not.That asymmetry is the whole argument for treating MDS accuracy as a revenue control, not a clinical formality.

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.

5 of 6
Components an MDS can move

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 PPS
75
Case-mix groups in total

16 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 PPS
3.00x
NTA front load, days 1 to 3

The 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 schedule
0.76
PT and OT factor, days 98 to 100

Therapy 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 schedule
100 days
Part A benefit period limit

Skilled 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 rules
3.2%
FY2026 net SNF PPS update

A 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 37310

Component 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.

ComponentGroupsWhat sets the groupVariable per diemWhere it leaks
Physical therapyPT component, priced per day16Section GG function score plus the clinical category derived from the primary reason for the skilled stay.Decays from day 21Function scored from a single observation rather than usual performance across the observation window.
Occupational therapyOT component, priced per day16Identical classification logic and the same function score as PT, which is why the two share one HIPPS character.Decays from day 21Any PT error is automatically an OT error. One GG defect moves two components at once.
Speech-language pathologySLP component, priced per day12Acute neurologic clinical category, defined SLP comorbidities, cognitive impairment, swallowing disorder, mechanically altered diet.Flat, no adjustmentSwallowing disorder and altered diet texture live in the chart but never reach the assessment.
NursingNursing component, priced per day25Extensive services, clinical conditions, the depression indicator, restorative nursing programs and the function score.Flat, no adjustmentRestorative nursing delivered daily but never documented to the frequency threshold.
Non-therapy ancillaryNTA component, priced per day6A weighted comorbidity and extensive service point score, collapsed into six groups.3.00 on days 1 to 3Comorbidities present on the hospital record that never get coded onto the MDS inside the lookback.
Non-case-mixRoom, board, administrativen/aNo resident characteristic changes it. It is the floor under every covered day.Flat, no adjustmentNot 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.

SNF benefit day router and the consolidated billing boundary ONE BENEFIT PERIOD, WITH THE DATE THAT CHANGES THE BILLING LANE Qualifying stayprecondition Part A, days 1 to 20covered, no coinsurance Part A, days 21 to 100covered, daily coinsurance Day 101 onwardPart A exhausted Reset60 days, noskilled care CONSOLIDATED BILLING BAND The facility owns nearly the whole service bundle. PART B LANE OPENS Therapy and ancillary services continue. LEAK POINTLEAK POINT An outside supplier bills Part B for a serviceinside the bundle. The claim rejects, then thesupplier invoices the facility months later.Without a pre-bill screen, it pays twice. A Part A only workflow stopsbilling at exhaust. The residentdays that follow generate noclaim at all. The exhaust date is knowable on the day of admission.That makes an unbilled post-exhaust day a workflow failure, not an information problem.
Consolidated billingWhat sits thereWho bills itAuthority
Inside the bundleThe facility paysAll 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 separatelyPhysician 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 categoriesComputed 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.

DimensionFee-for-service, PDPMMedicare Advantage
Rate structureSix 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 rateThe 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 stayPT 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 controlCoverage criteria and the 100 day benefit period limit.Prior authorization and concurrent review, on the plan clock.
Dominant denial patternAssessment 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 criteriaMedicare 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 wonIn 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.

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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