“Using the authority under Section 1812(f) of the [Social Security] Act, CMS waived the requirement for a 3-day prior hospitalization for coverage of a SNF stay, which provides temporary emergency coverage of SNF services without a qualifying hospital stay, for those people who experience dislocations, or are otherwise affected by COVID-19,” the agency wrote.

It’s this portion of the three-day stay waiver that might fall under some scrutiny, particularly as CMS plans to take a close look at Medicare claims throughout 2020 with an eye to recalibrating the Patient-Driven Payment Model (PDPM). To date, we are already hearing about government audits, etc.

The reimbursement overhaul for Medicare payments to SNFs that took effect in 2019 ended up increasing payments to nursing homes by about 5% in 2020. CMS pointed to the use of the waiver suspending the three-day stay requirement as an indicator that the increase couldn’t be attributed to COVID-19 changes alone.

– “Post-Pandemic, SNFs Should Expect Government Scrutiny on Use of Three-Day Stay Waiver” – Maggie Flynn

Be sure you have all of your ducks in a row, and be sure your documentation supports your use of the wavier appropriately and as intended by CMS. After a hard year of COVID-19 and infection control surveys, the last thing you need is to be scrutinized for your billing practices!

Stay well and stay tuned!