The role of Consolidated Billing as it relates to SNFs:

The consolidated billing requirement confers on the SNF the billing responsibility for the entire package of care that residents receive during a covered Part A SNF stay and PT, OT and ST received during a non-covered stay.

For more detailed information see:

Even though non-therapy services may get billed by the individual providers under Part B, therapy services cannot. Quoting from page 2 of CMS’ Medlearn Matters Number SE0518: “The consolidated billing legislation is very emphatic that PT, OT and SLP services furnished to SNF residents are always subject to consolidated billing…” Said another way, any therapy service, regardless of provider or location (e.g. Hospital, mobile MBS truck, etc) is subject to the same rules and regulations.

Also further down on page 2: “In a non-covered SNF stay, the beneficiary may be eligible for coverage of individual medical and other health services under Part B. Since the beneficiary still resides in a Medicare-certified institution (or part thereof) the therapy services are subject to the SNF consolidated billing provision. Under this provision, the claims for therapy services furnished during a non-covered SNF stay must be submitted to Medicare by the SNF itself. The SNF is responsible for reimbursing the provider. The SNF would bill its fiscal intermediary and be reimbursed under the Medicare fee schedule.”

Frequently Asked Questions: FAQs

1. But I seem to be getting my Modified Barium Swallow Studies (MBSS) for “free”, how is that?

Identify if you are actually getting the MBSS for free. It may come billed as many different services, including Radiology time, fluoroscopy suite rental, etc. Or the bill may come less frequently than once per month. The rules are clear, therapy services fall under Consolidated Billing regardless of the site of care. Also recall the other costs associated with sending patients out: transportation costs, loss of rehab productivity time for all therapy services, cost of delay of getting the report back, cost of long scheduling time, etc.

2. But Consolidated Billing rules only cover Part A patients, right?

No. The rules are clear. All therapy services (both Part A and B) fall under the Consolidated Billing rules.

3. What about if I’m getting the MBSS done by a portable truck and not by the hospital?

Again, the Consolidated Billing legislation is very emphatic that PT, OT and SLP services furnished to SNF residents are always subject to consolidated billing. A Modified Barium Swallow Study is a therapy service.

4. What is “unbundling” a therapy service?

Prior to the Balanced Budget Act of 1997, it was typical for the SNF to permit an outside supplier to furnish the service directly to the resident and the outside supplier would submit a bill to Medicare Part B, without any involvement of the SNF itself. This practice created many problems and thus was the whole reason the Consolidated Billing rules were enacted. The new rules eliminates the potential for duplicative billings for the same service… also enhances the SNF’s capacity to meet its existing responsibility to oversee and coordinate the total package of care that each of its residents receives. See website:

5. Are there some services that don’t fall under Consolidated Billing?

Yes. There is a listing of such services and they include such things as physician services, cardiac catherterizations, MRIs and emergency services, etc. But not PT, OT or ST therapy services. You can find those listed at the website: