The COVID-19 100-Day Benefit Waiver for Skilled Nursing Facilities (SNFs) is a temporary measure implemented by the Centers for Medicare & Medicaid Services (CMS) to help alleviate some of the challenges posed by the pandemic. The waiver allows for the provision of skilled nursing and/or skilled rehabilitation services to Medicare beneficiaries without the usual requirement of a three-day hospital stay prior to admission to the SNF, and for certain beneficiaries who recently exhausted their Skilled Nursing Facility (SNF) benefits, the COVID-19 100-Day Benefit Waiver authorizes renewed SNF coverage without first having to start a new benefit period.
This means that beneficiaries who have exhausted their SNF benefits before the waiver was implemented, or during the Public Health Emergency, are eligible for renewed coverage under the waiver without having to meet the usual requirement of a three-day hospital stay or starting a new benefit period.
This waiver is in effect during the Public Health Emergency (PHE) and it's important to note that the waiver is being extended periodically.
Currently, the last day of the PHE is April 11, 2023.
HHS, Health and Human Services in D.C. must give the SNF Industry a 60-day notice.
That means, providers should know whether the COVID-19 Waiver will be extended
beyond April 11, 2023
February 10, 2023.
Please advocate for an extension!
Under the waiver, beneficiaries can be admitted to a SNF directly from the hospital or from the community if they meet the clinical criteria for skilled nursing or rehabilitation services.
Additionally, the waiver also allows for the provision of certain therapies on a more frequent basis, such as physical, occupational, and speech therapies.
Skilled Nursing Facilities (SNFs) that participate in the Medicare program are required to bill for services provided to beneficiaries under the COVID-19 100-Day Benefit Waiver using the standard SNF Billing Codes. This means that SNFs should not bill for services covered by the waiver as "COVID-19-related" services.
SNFs should bill for services using the standard SNF Part A Billing Codes, including the following:
- The SNF's daily rate for room and board, as well as for any additional services provided, such as physical, occupational, and speech therapies.
- The SNF's per diem rate for therapy services provided to beneficiaries under the waiver.
- The SNF's per diem rate for additional services provided to beneficiaries under the waiver, such as nursing and other ancillary services.
- SNFs should also continue to submit claims to Medicare using the standard claims forms and procedures. The claims should be submitted to the Medicare Administrative Contractor (MAC) that processes claims for the SNF's service area.
SNFs must continue to comply with all other Medicare requirements, including those related to infection control, quality of care, and resident rights, even when providing services under the waiver. Also, for the billing process, it is important to consult with the MAC for the specific instructions and guidelines regarding the billing process for the COVID-19 100-Day Benefit Waiver.
The Public Health Emergency (PHE) for COVID-19 was declared by the Secretary of Health and Human Services (HHS) on January 27th, 2020 and is ongoing. The declaration of a PHE allows the Secretary to waive or modify certain requirements under the Medicare, Medicaid, and Children's Health Insurance Programs (CHIP) to provide more flexibility for providers and patients.
The duration of a Public Health Emergency (PHE) is not fixed, it can be extended periodically by the Secretary of Health and Human Services (HHS) if the emergency continues to exist. The Secretary may also terminate a PHE at any time if the emergency no longer exists.
It is important to note that the end of the Public Health Emergency (PHE) will impact the availability of certain waivers, such as the COVID-19 100-Day Benefit Waiver for Skilled Nursing Facilities (SNFs) and the other waivers, that were implemented during the emergency, and those waivers will be rescinded once the PHE is over.
It is important to keep in mind that the duration of the Public Health Emergency (PHE) is constantly evolving, and it's subject to change based on the ongoing situation of the pandemic.