President Trump’s National Emergency Declaration, Friday the 13th provided clarification surrounding dramatic changes to our SNF setting of care. In an effort to combat and contain the spread of COVID-19, CMS waived the 3 day prior hospitalization requirement [Section 1812 (f) of the Social Security Act] for coverage of a skilled nursing facility (SNF) stay providing temporary emergency coverage of SNF services without a qualifying hospital stay.
A Few Key Points
surrounding this waiver as well as other measures CMS released Friday in efforts to protect our most vulnerable of populations:
Visitation Restrictions:
All visitors, volunteers and non- essential health care personnel are now restricted. End of life visitation being an exception handled on a case-by-case situation
Cancellation of all group activities and communal dining:
Rehab Delivery Strategies / Reminders:
- thorough hand washing and disinfecting of equipment between each resident (no shared theraputty!!!)
- safe distancing of 6 feet between residents if concurrent or gym setting treatments are being delivered
- one on one therapy sessions
- treatment in patient rooms for anyone at highest of risk or presence of respiratory infection symptoms (fever, cough, shortness of breath, sore throat)
- constant assessment of rehab team members for signs and symptoms of potential infection
- FOLLOW provider, state and federal guidelines
3 Day Waiver: Freeing hospital beds and containing potential risk to our patients and others
Criteria – must meet Medicare Manual Skilled Services Definitions (not limited to COVID-19 Dx – follow CMS releases closely for additional details)
Opens potential for Direct Admissions from Community – Ex: ED direct admit to SNF if established skilled need, or recent DC to community has a decline warranting skilled care that is able to be met in SNF vs Acute Hosp with physician guidance
Renewed SNF Coverage without having to start a new benefit period for ‘certain beneficiaries who recently exhausted their SNF benefits’
CRITICAL DOCUMENTATION:
Physicians determination of daily skilled care being medically necessary and indicated
- Complexity and frequency of needs for skilled services require in-patient setting.
– Requires multiple skilled treatments daily
– Need for daily skilled services exceeds care available at lesser levels such as HH
Services provided daily by or under the supervision of skilled nursing or therapy staff
- Observation and Management of Care Plan (Ex: fever, cough, SOB, sore throat requiring close skilled monitoring and assessment)
- EX skilled services: IV fluids, IV meds, Respiratory Treatments
Above and additional points are included in the press releases below from Friday the 13th linked below:
- CMS’ Announcement of New Measures to Protect Nursing Home Residents: https://www.cms.gov/newsroom/press-releases/cms-announces-new-measures-protect-nursing-home-residents-covid-19
- Press Release following National Emergency Friday, March 13th: https://www.cms.gov/newsroom/press-releases/cms-takes-action-nationwide-aggressively-respond-coronavirus-national-emergency
Let’s Get to the Point:
Protect Yourself and Our Vulnerable Population!
