SNFs Have Waived the Three-Day Rule

By  |  March 18, 2020 | 

Post-acute care, and in particular SNFs, are changing policies day to day, and visitation restrictions, cohorting, capacity to manage varying levels of patient acuity, and telemed capacity will vary site to site. Please note the change in CMS regulatory policy below. SNFs have waived the three-day rule:

Skilled Nursing Facilities 

CMS is waiving the requirement at Section 1812(f) of the Social Security Act for a 3-day prior hospitalization for coverage of a skilled nursing facility (SNF) stay provides temporary emergency coverage of (SNF services without a qualifying hospital stay, for those people who need to be transferred as a result of the effect of a disaster or emergency. In addition, for certain beneficiaries who recently exhausted their SNF benefits, it authorizes renewed SNF coverage without first having to start a new benefit period. Second, CMS is waiving 42 CFR 483.20 to provides relief to SNFs on the time frame requirements for Minimum Data Set assessments and transmission.

HERE is the CMS guidance doc. Its full of updates for IRF, LTACH, etc. (and it’s a short read).

Hospital leadership will likely use one part planning and one part improvisation to streamline mild to moderately ill patients into skilled care. Whether local SNFs will have the capacity or want to take patients remains to be seen. However, as the crisis progresses, we might see designated SNFs manage some Covid patients only–with their non-Covid long-term and short term care patients transferred to the home of relatives or other non-designated SNFs. Payments and figuring out the finances will come later. Logistics and making things work will be an altogether rational (we hope) and spontaneous affair.

POSTSCRIPT HERE.

POSTSCRIPT #2: AMDA has released a resolution on how facilities should manage transfers in the time of Covid. What it boils down to is no negative test, no transfer. Smart policy for nursing homes but it complicates the decanting pipeline. Statement below. We need designated SNFs to manage Covid (+)  or high-risk volume.

SHM continues to actively monitor the evolving COVID-19 outbreak and remains dedicated to providing a forum to share best practices and experiences to help prepare hospitalists for the COVID-19 response. SHM’s compilation of COVID-19 resources can be found at hospitalmedicine.org/coronavirus.

 

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About the Author: Bradley Flansbaum

Bradley Flansbaum
Bradley Flansbaum, DO, MPH, MHM works for Geisinger Health System in Danville, PA in both the divisions of hospital medicine and population health. He began working as a hospitalist in 1996, at the inception of the hospital medicine movement. He is a founding member of the Society of Hospital Medicine and served as a board member and officer. He speaks nationally in promoting hospital medicine and has presented at many statewide meetings and conferences. He is also actively involved in house staff education. Currently, he serves on the SHM Public Policy Committee and has an interest in payment policy, healthcare market competition, health disparities, cost-effectiveness analysis, and pain and palliative care. He is SHM’s delegate for the AMA House of Delegates. Dr. Flansbaum received his undergraduate degree from Union College in Schenectady, NY and attended medical school at the New York College of Osteopathic Medicine. He completed his residency and chief residency in Internal Medicine at Long Island Jewish Medical Center in New York. He received his M.P.H. in Health Policy and Management at Columbia University. He is a political junky, and loves to cook, stay fit, read non-fiction, listen to many genres of music, and is a resident of Danville, PA.

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