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 #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.