Q: Who is responsible for billing for ED services when the patient is discharged from an IPF to the ED and returns to the IPF within the same day?

Question: Who is responsible for billing for emergency department services when the patient is discharged from an Inpatient Psychiatric Facility (IPF) to the emergency room and returns to the IPF within the same day?

 

Answer: The status of discharge is what determines payment responsibility. Decisions regarding appropriate site of care for Inpatient Psychiatric Facility (IPF) admissions and discharges are made by the attending physician. First, the patient should not be discharged from the IPF when there is a reasonable level of expectation that the patient will return to the IPF within the same day. Nevertheless, if a patient is discharged, any subsequent services they receive are billed by the provider of those services, whether it is an Emergency Room (ER), hospital, etc. If the patient had never been officially discharged from the IPF, the IPF would be responsible for all of the patient’s subsequent charges. While the person is an inpatient of the IPF, the IPF must furnish all necessary covered services to a Medicare beneficiary. Therefore, if the patient has not been discharged, the cost of the ED services is the responsibility of the IPF. See § 412.404(d)(3).