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We keep learning about new measures the government and the public institutions are putting in place to address the COVID-19 emergency. New PDPM updates are coming, cuts are being delayed, and financial requirements are being waived in favor of our healthcare system’s enforcement. Today we are talking with Sue Friesth about Coronavirus waivers to learn more about these changes and what they mean for SNFs.

We have interviewed Sue Friesth, NetSolutions’ Financial Product Manager, to walk through these updates and the coronavirus waivers CMS launched to help Skilled Nursing Facilities (SNFs) and their residents combat the challenges brought on by COVID-19. 

This article will walk you through how the affected policies traditionally worked, what the waiver changes mean for your facility, and how you can properly bill your residents under the new conditions.

More specifically, the governmental waivers apply to two primary financial policies:

  • The Qualified Hospital Stay 
  • 100-Day Benefit Period

Qualified Hospital Stay Coronavirus Waivers

Also known as the 3-Day Stay, this traditional Medicare policy requires the beneficiary to have a hospital stay of at least three consecutive days to qualify for Medicare coverage in a Skilled Nursing Facility.

Coronavirus Waivers for nursing home resident

How the CMS Waiver Changes the Qualified Hospital Stay Rules

The new CMS waiver implies that all residents requiring skilled care are eligible for the three-day inpatient qualifying hospital stay waiver benefit. The waiver applies to all residents because all hospitals nationwide are being affected by the COVID-19 pandemic. Many hospitals can’t afford to host patients for the full three days, so Medicare now takes care of Skilled Nursing Facilities coverage.

Billing Under the Qualified Hospital Stay Waiver

All providers need to do when processing bills under the Qualified Hospital Stay Waiver to ensure their reimbursements include the condition code DR (Disaster-Related) in their claims. 

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100-Day Benefit Period Waiver

The Medicare benefit coverage traditionally only covers a new SNF resident for up to 100-days. When the 100-days period is over, Medicare won’t cover the resident’s care in the facility. Only after the resident hasn’t been a hospital or SNF inpatient during a 60-day break, does the resident qualify for another 100-day benefit period.

What the CMS Waiver Changes

LTC Resident

The new CMS waiver enables residents to qualify for a one-time renewal of their 100-day benefit period. Since this is a COVID-related exception waiver, it comes with contextual conditions. 

Residents are only eligible to extend their Medicare coverage with the 100-day waiver period if their healthcare is affected by the COVID-19 emergency while being an inpatient in a Skilled Nursing Facility. For example, this would include a resident contracting COVID-19 during their inpatient period in a facility or pandemic-related therapy treatment interruptions.

To determine if the resident qualifies for the waiver, the facility must compare the resident’s received treatment to what would have been provided if there was no COVID-19 emergency. If the two courses of treatment are precisely the same, then the waiver would not be allowed.

Billing Under the 100-Day Benefit Period Waiver

For billing purposes, when a resident is eligible for the waiver, the facility must follow the following instructions: 

  1. Submit a final discharge claim with patient status 01.
  2. Readmit the beneficiary on day 101 to start the beneficiary period waiver.
  3. Complete a 5-day PPS assessment.
  4. Submit the new claims with the PDPM score from the new assessment. The Variable Per Diem schedule starts on Day 1.
  5. Use condition code DR.
  6. Use condition code 57 (readmission to bypass edits related to the 3-day stay within 30 days).
  7. Include  COVID100 in the remarks to identify the claim as a benefit period waiver request.
  8. Make sure to fully document in the medical records that the skilled care meets the waiver requirements – this may be subject to post-payment review.
  9. Once the second 100-day benefit is exhausted, follow existing requirements for No-Pay claims until the resident is discharged.  Benefits exhaust no-pay claims relating to the benefit waiver should include the condition code DR and “BENEFITS EXHAUST” in the remarks.

Other CMS Updates Announced

Medicare Sequestration Cuts

In addition to these two waiver updates, congress also passed the delay of the 2% Medicare sequestration cuts suspended through December 31st, 2020, in one of the early stimulus packages. Consequently, sequestration cuts will be further delayed until the end of March 2021.

PDPM Update on ICD 10 Codes 

The CMS has also announced a PDPM update that will include new ICD 10 codes to adapt providers’ MDS assessments to the different types of COVID-19 infection preventionists can confront. The PDPM data specs have been updated to indicate when the codes are appropriate for item I0020B and to reflect the mapping of the new codes to clinical categories. The new codes can be used effective January 7, 2021.

Need More Guidance and Resources?

The following link provides guidance and resources for our Covid-19 vaccine and dashboard monitoring system to help your team manage the impact of the pandemic.

If you need further assistance, do not hesitate to contact NetSolutions support. We will update you on everything you need to know to keep your facility on track to effectively face new challenges.

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