Published December 11, 2020

With the rise in COVID cases nationally, endless regulatory changes, reimbursement cuts and soaring costs, it would be wise for skilled nursing leadership to regroup with their operational, clinical and reimbursement teams to review the facilities infection control and 1135 waiver application practices.

Coretactics has put together some reference material and web links to help your team navigate this sea of changes.  We know all this information can be overwhelming. Please reach out to us if you need assistance implementing the 1135 waiver, ensuring reimbursable items are not left behind or ensuring you have a strong compliance program when the highly predicted targeted probes (i.e., focused audits) and requests for additional documentation hit your facility.

1135 Waiver Tips & Review:

• 3 day qualifying hospital stay:  CMS is waiving the requirement for a 3-day prior hospitalization for coverage of a SNF stay.  SNF care without a 3-day inpatient hospital stay will be covered for beneficiaries who experience dislocations or are otherwise affected by the emergency, such as those who are (1) evacuated from a nursing home  in the emergency area, (2) discharged from a hospital (in the emergency or receiving locations) in order to provide care to more seriously ill patients, or (3) need SNF care as a result of the emergency, regardless of whether that individual was in a hospital or nursing home prior to the emergency.
• 60-Day Wellness Benefit:  Per CMS, for certain beneficiaries who exhausted their SNF benefits, it authorizes renewed SNF coverage without first having to start and complete a 60-day “wellness period”.  This waiver will apply only for those beneficiaries who have been delayed or prevented by the emergency itself from commencing or completing the 60-day wellness period.
• Staffing/PBJ Reporting:  Important!  In case you missed it, submission of staffing data through the Payroll Based Journal system was reinstated on June 25, 2020 beginning with Q2 2020 and CMS resumed updating the staffing domain of the Five Star system in October 2020. The next PBJ submission for calendar quarter 4 staffing is due Feb. 14, 2021.
  • • SNF QRP and VBP Exceptions/Extensions:  Providers are excepted from the reporting of data on measures and standardized patient assessment data required under these programs for the post-acute care (PAC) quality reporting programs (QRP) for calendar years (CYs) 2019 and 2020 for the following quarters.
      • • • October 1, 2019–December 31, 2019 (Q4 2019)
          • January 1, 2020–March 31, 2020 (Q1 2020)
          • April 1, 2020–June 30, 2020 (Q2 2020)
            
            SNF VBP – CMS will exclude qualifying claims from the claims-based SNF 30-Day All-Cause Readmission Measure
            (SNFRM; NQF #2510) calculation for the following periods:
          • January 1, 2020–March 31, 2020 (Q1 2020)
          • April 1, 2020–June 30, 2020 (Q2 2020)

Helpful web links and resources:
https://www.cms.gov/files/document/se20011.pdf
https://www.cms.gov/files/document/covid-long-term-care-facilities.pdf