How to Build a Part B Reimbursement Review Process for Your SNF

External supply vendors submit Medicare Part B claims under their own NPI. The reimbursement goes to them, not to the facility. The facility has its own billing rights for surgical dressings, urological supplies, ostomy supplies, tracheostomy supplies, and splints. Most facilities have never used them.

That is what a Part B supply reimbursement review process fixes. Building one is less complicated than most administrators expect once they see what it actually involves.

How Do You Build a Part B Reimbursement Review Process for a Skilled Nursing Facility?

A Part B supply reimbursement review process runs through five connected stages: identify which supplies fall into Part B-billable categories, verify resident payer status on the delivery date, confirm documentation (signed order, chart support, and proof of delivery or usage), code and submit under the facility's NPI, and track results including held, excluded, and never-submitted items. Each stage needs a defined owner and a handoff to the next.

Why Most SNFs Do Not Have This Process

The external supplier model did not emerge because facilities were negligent. It emerged because Part B supply billing required infrastructure that vendors had and facilities did not: billing departments, clearinghouses, payer relationships. Vendors stepped in, absorbed the function, and kept the reimbursement. The facility got used to not seeing it.

CMS has since identified roughly $1.9 billion in improper payments linked to this model, largely claims submitted by external suppliers without adequate documentation review or resident payer status verification. Supplies delivered during covered Medicare Part A stays were billed separately at scale, while the facility sat on the sidelines with billing rights it had never exercised. For the warning signs that surface first, see Medicare billing red flags SNF leaders should not ignore.

Under 42 U.S.C. § 1395x(s) and 42 CFR 411.15(p)(2), certain Part B supplies are carved out from SNF consolidated billing and remain separately billable by the facility when the resident is not under a covered Part A stay. CMS Pub. 100-04, Chapter 7, §§ 10 and 60 provide the billing instructions. The pathway exists. Most SNFs have simply never built a process to walk it.

Stage 1: Identify Billable Supplies

The first stage surfaces which supplies, delivered to which residents, fall into Part B-billable categories. For most SNFs that means surgical dressings, urological supplies, ostomy supplies, tracheostomy supplies, and certain splints and orthotics. Enteral nutrition is billable under Medicare Advantage but not traditional Medicare in the SNF context, so that boundary belongs in the identification logic from the start.

For facilities using PointClickCare, the data already exists: resident supply records, MAR entries, and care plan documentation. A read-only connection that pulls this into a review workflow removes the manual step of reconstructing deliveries from paper records or vendor invoices. See the PointClickCare billing integration for how that connection works in practice.

Stage 2: Verify Payer Status

Stage 2 is where informal review processes typically break down. A supply can be in a billable category and still not be separately billable if the resident was under a covered Medicare Part A stay on the delivery date. Consolidated billing places those items inside the Part A bundled payment, and a separate Part B claim for them is a billing error regardless of how clean the documentation is.

Timing matters. Residents move between Part A, Part B, and other payer statuses throughout a stay. The check has to reflect the actual status on the delivery date, not the status at the time of billing review. For the underlying distinction, review Medicare Part A vs Part B in SNFs.

Every supply that clears Stage 2 gets a confirmed payer status on record. Every supply that does not gets documented as held or excluded, with the reason recorded.

Stage 3: Confirm Documentation

Three things have to be in place before a claim moves forward.

• The signed order. For certain dressings, urological supplies, and other categories, a Standard Written Order is required before delivery. An order dated after the supply was already in the room does not count.
• The clinical documentation. A wound care assessment, nursing note, or care plan entry that connects the item to the clinical need. Medical necessity is not something the billing team infers; the chart proves it.
• Proof of delivery or usage. A MAR entry, delivery confirmation, or usage note. Without it, the claim is exposed regardless of how clean the order and chart are.

A signed order with weak chart documentation is still a problem. Clean chart documentation with no delivery confirmation is still a problem. Stage 3 confirms all three connect before coding. For the patterns that recur most often, see common Medicare Part B documentation gaps in skilled nursing.

Stage 4: Code and Submit Under the Facility's NPI

With payer status confirmed and documentation complete, the supply gets coded and the claim goes out under the facility's own NPI. Coding requires matching the supply to the correct HCPCS code, confirming the unit, and aligning the service date with the documentation. Code, unit, and date in the billing record have to match what the chart says. A unit count that does not match the delivery confirmation gets flagged regardless of what else is in order.

Reimbursement flows back to the facility's bank account via ERA. That is the structural difference from the external supplier model, and it is the whole reason to build the process. See Medicare Part B supply reimbursement for how the submission workflow runs end to end.

Stage 5: Track and Close the Loop

A review process that ends at submission leaks at the far end. Stage 5 tracks every claim that goes out as paid, denied, or pended. Every denial gets a reason code, a review, and a determination: resubmit, appeal, or close. Every pended claim gets a follow-up date.

The tracking layer also has to surface three categories most billing workflows miss.

The denied claim costs on the reimbursement side. The claim that was never submitted costs on both sides: missed revenue and a process that does not know what it is missing. Keeping both visible is also what makes the process defensible, as covered in how to maintain audit readiness while recovering missed revenue.

Who Owns This Process

Part B supply billing review does not require a new hire. It requires defined handoffs between clinical documentation, payer status tracking, supply records, and billing submission. In practice that usually means one person who confirms that Stage 1 identification runs each cycle, that Stage 2 status checks happen before submission, that Stage 3 documentation is confirmed rather than assumed, that Stage 4 claims go out clean, and that Stage 5 tracking produces a report leadership can read without interpretation.

That person does not need to be a billing specialist. They need process discipline, access to the right systems, and a clear owner for each handoff.

The 12-Month Lookback

When a facility builds a Part B supply review process for the first time, the first run does not just cover current claims. Most MACs accept Part B supply claims up to 12 months from the date of service. A facility that has never had a formal review process may have months of potentially recoverable reimbursement sitting in the record: supplies that were delivered, documented, and within the filing window but never submitted.

What the Process Produces for Leadership

• A monthly reimbursement report. Records reviewed, moved to billing, held, excluded, and recovered. One page, once a month.
• A documentation gap log. What is routinely missing at Stage 3 and where the clinical documentation process needs tightening.
• A compliance record. Every hold and every exclusion documented with a reason, so the answer to an auditor's question is traceable: reviewed, excluded, reason on file.

The third one matters as much as the first. It is the difference between a defensible process and a gap someone else gets to characterize. For audit-specific support, see Medicare audit defense for SNFs.

How Burst Billing Fits Into This

Burst Billing works with skilled nursing facilities to build and run this process for the Part B supply categories where the reimbursement potential is clearest: surgical dressings, urological supplies, ostomy supplies, tracheostomy supplies, and splints and orthotics.

The process starts with a PointClickCare read-only Marketplace integration, runs a 12-month lookback analysis on the facility's supply records, submits claims under the facility's own NPI, and routes ERA directly to the facility's bank account. A BAA is executed before any data access. The model is contingency-based: no setup fee, no monthly minimum, no software license. If there is no recovery from supported claims, there is no fee. See the contingency-based billing model for details.

To see what your current Part B supply billing record actually looks like, contact Burst Billing for a free assessment.

Compliance Note

This article is for general educational purposes only and does not replace facility-specific billing, compliance, legal, or payer guidance. SNFs should verify coverage, coding, documentation requirements, and submission decisions against current CMS guidance, payer rules, and their own compliance policies.

References

• CMS, Skilled Nursing Facility (SNF) Consolidated Billing
• CMS, Medicare Claims Processing Manual, Pub. 100-04, Ch. 7
• CMS, Medicare Coverage Database