Skilled Nursing Care: Medicare Part A Coverage
Legal Eagle Eye Newsletter for the Nursing Profession
April 1998
Quick Summary: Medicare Part A covers post-hospital extended care services where a physician (or a nurse practitioner or clinical nurse specialist who is not employed by the care facility but who is working with a physician) certifies that the patient needs skilled nursing care or other skilled rehabilitation services on a daily basis.
The patient must need these skilled services for the condition for which the patient had received inpatient hospital services prior to transfer to the skilled nursing facility.
UNITED STATES DISTRICT COURT, WISCONSIN, 1997.The patient was sixty-eight years old and enrolled in Medicare. She was treated in the hospital for a hip fracture, then went to a skilled nursing facility. Medicare benefits were denied for a substantial portion of the time she was in the facility. She was asked to pay privately for the time in the facility after which Medicare said it would not pay. She filed an appeal.
The U.S. District Court for the Western District of Wisconsin ruled against the patient’s appeal. The court noted that after a certain date, the patient needed and was receiving physical therapy only three days per week.
Physical therapy qualifies as a skilled rehabilitative service, and it was for the hip fracture for which the patient was hospitalized. But it was not needed or rendered on a daily basis, the court pointed out.
Dale by Dale v. Shalala, 984 F. Supp. 1206 (W.D. Wis., 1997).