CMS COVID-19 Guidance for SNFs on Three-Day Hospital Stay

Thoughtware Alert Mar 19, 2020
Patient and Nurse

We’re receiving frequent updates on how the president’s declaration of a national emergency is affecting skilled nursing facilities (SNFs). We’ve received multiple questions on the three-day inpatient hospital stay being waived and want to provide you with additional clarification. CMS’ goal of waiving the three-day qualifying stay is to free up hospital beds, permit all qualifying patients to enter SNFs as quickly as possible and limit the spread of the virus.

Informal guidance suggests:

  • The waiver only applies to original Medicare.
  • The waiver applies to all patients who require skilled care—they don’t have to specifically have the COVID-19 diagnosis.
  • SNFs don’t have to demonstrate the hospital or referring facility was evacuated due to COVID-19.
  • SNFs don’t need to demonstrate the patient was discharged from the hospital due to COVID-19 or even so the SNF could provide care to more serious patients at the hospital.
  • SNFs don’t need to demonstrate the patient needs care because of COVID-19, whether in the hospital or nursing home prior to the emergency.
  • CMS hasn’t placed any limits on the types of admissions, so SNFs may admit residents from hospitals with less than three midnights, hospital observation or emergency rooms, as well as residents directly from the community including their own residents who have a change in condition that now requires a skilled level of care.

To qualify for the waiver, all patients must meet the criteria for skilled care, and this should be supported by documentation. The waiver applies to all SNFs nationwide, so there’s no need to apply for individual waivers. The waiver expires when the national emergency ends, and providers will be informed by the U.S. Department of Health & Human Services or CMS. For claims to process without the three-day qualifying hospital stay, condition code “DR” should be included on the UB-04 claim form.

Guidance related to COVID-19 is evolving quickly and subject to change. BKD has created a COVID-19 Resource Center to help disseminate important information for our clients and friends as we evaluate ways to mitigate the inevitable financial effects. In addition, CMS issued a Q&A document that addresses this topic. If you have questions, please reach out to your BKD Trusted Advisor™ or use the Contact Us form below.

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