The Centers for Medicare & Medicaid Services (CMS) has issued its July 2025 quarterly update to the Healthcare Common Procedure Coding System (HCPCS) codes used for enforcing the Consolidated Billing (CB) provision of the Skilled Nursing Facility (SNF) Prospective Payment System (PPS). The effective date for these changes is July 1, 2025, with an implementation date of July 7, 2025.
CMS uses these quarterly updates to align HCPCS and CPT code changes and Medicare Physician Fee Schedule designations with SNF CB policy. These updates revise edits in the Common Working File (CWF), ensuring that Medicare Administrative Contractors (MACs) apply correct payment rules under SNF CB. The changes reflect coding system maintenance, not a policy shift in the scope of services subject to CB.
As with prior updates, certain categories of services are impacted. The July 2025 update includes changes affecting angiography, lymphatic, venous, and related procedures, chemotherapy, radioisotopes and their administration, blood clotting factors used to treat hemophilia and similar bleeding disorders, and customized prosthetic devices. CMS continues to exclude certain services from SNF CB, meaning Medicare may pay providers other than the SNF for these services, even during a SNF stay. For services not excluded, only the SNF may bill Medicare.
For non-therapy services, the CB provision applies only during a covered Medicare Part A stay. However, for therapy services—including physical therapy, occupational therapy, and speech-language pathology—CB applies whenever services are furnished to a SNF resident, regardless of whether the stay is covered under Part A. CMS updates its claims systems to ensure correct payment for all services, whether they are included in or excluded from SNF CB.
The July 2025 update includes a list of HCPCS code changes affecting SNF Consolidated Billing. The update outlines which codes are being added or removed from the Part A and Part B files, with changes to Part A effective April 1, 2025. While Medicare Administrative Contractors (MACs) won’t automatically review previously paid claims for these codes, they will reopen and reprocess claims if requested, provided the claim relates to the updated codes.
CMS has released this guidance to ensure SNFs and other providers are aware of the latest coding updates and billing responsibilities under SNF CB. The full instruction set is available through your MAC, and updated HCPCS code files are now posted for institutional and professional billing.
Compliance Perspective
Issue
Updates to HCPCS and CPT codes related to Skilled Nursing Facility Consolidated Billing (SNF CB) are released on a regular basis by CMS. Staying informed of these updates helps ensure accurate billing and compliance with Medicare requirements. Incorrect billing, even if unintentional, can result in claim denials or payment errors that require correction. As with any coding or reimbursement change, reviewing practices and ensuring staff awareness are important steps in maintaining billing accuracy.
Discussion Points
- Review your policies and procedures related to SNF Consolidated Billing. Update them to reflect the July 2025 quarterly HCPCS and CPT code changes, including any additions or deletions. Ensure that processes clearly identify which services must be billed by the SNF and which are excluded under CB provisions.
- Provide training for billing and administrative staff on the latest HCPCS and CPT updates. Emphasize the importance of knowing which services are covered by SNF CB and how to report any billing issues or concerns.
- Audit to confirm billing accuracy and identify any discrepancies related to CB billing. Include audits of both claims and staff understanding to ensure that code changes are being applied correctly and that appropriate procedures are followed for identifying and addressing errors.
*This news alert has been prepared by Med-Net Concepts, Inc. for informational purposes only and is not intended to provide legal advice.*