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Category: SNF PPS

IMPORTANT COVID-19 FUNDING UPDATE | MAY 22, 2020

May 23, 2020

This Sunday, May 24, is the deadline for attesting to CARES provider relief payments received on April 10.

Toyon’s COVID-19 Funding Resources (updated for interactive national modeling of funding)
Toyon University’s COVID-19 Funding and Documentation Presentation

Wednesday, June 3, is the deadline to submit COVID-19 expenses for
additional provider relief funding. Providers may be eligible for payments
from the remaining
funds through targeted distributions.
Toyon estimates $27.6
billion in unallocated
funding.

Toyon is pleased to provide this update on developing details from the CARES Act Public Health and Social Services Emergency Fund (PHSSEF). For more information, or to contact any of our team members, please feel free to check Toyon’s website.

Important Deadlines: May 24 and June 3
This Sunday, May 24 is the deadline for providers receiving CARES PHSSEF payments on April 10 to attest the terms and conditions (T&C).

Providers that do not attest to the T&C and retain the funds past 45 days will retain payments and be included in HHS’s public release of providers and payments. In HHS’s updated FAQs, the agency states:

“Generally, HHS does not intend to recoup funds as long as a provider’s lost revenue and increased expenses exceed the amount of Provider Relief funding a provider has received.”

Providers must also submit revenue detail by June 3 to receive additional funding from the PHSSEF Distribution.
Please visit Toyon University’s COVID-19 Funding and Documentation Presentation for a discussion on submitting expenses and revenue loss. In HHS’s updated FAQs, HHS indicates this information may be used for other funds, such as the High Impact Fund. HHS states:

“Providers should update their capacity and COVID-19 census data to ensure that HHS can make timely payments in the event that the provider becomes a high-impact provider. Providers can continue to update their information through the same method they used previously.”

Also, providers are required to accept HHS’s T&C and submit revenue information to be considered for additional relief payments.

Toyon’s estimation of unallocated funds (to eligible hospitals) from the CARES Act PHSSEF is below. It is noted some of this funding will be used as part of provider relief funding for skilled nursing facilities (SNF) and HRSA’s Uninsured Program.

$50,000 Payments to RHCs for COVID-19 testing | expenses
Also included in HHS’s provider relief funding update is a distribution of $225 million to RHCs for COVID-19 testing. Payments are based on the number of certified clinic sites. HHS also released RHC T&Cs here.

Provider relief for Skilled Nursing Facilities
As part of the CARES provider relief funding, HHS is distributing $50,000 to each SNF plus a variable distribution between $2000 per bed for smaller SNFs (5 and 25
beds) and $1,8000 per bed for larger SNFs (more than 200 beds). HHS also released SNF T&Cs here.

Thank you

Toyon is committed to apprising providers with important reimbursement updates and will keep you updated with the latest on UC DSH and COVID-19 funding and documentation. Please feel free to visit Toyon’s COVID-19 Resources for updates on hospital funding estimates, recommendations on documenting cost and revenue losses associated with this public health emergency. Toyon’s website provides information on how to contact Toyon’s team members.

COVID-19 Regulatory Changes

March 17, 2020

President’s National Emergency Declaration; CMS COVID-19 Fact Sheet

For more information regarding CMS Current Emergency response and issuances, use the link below:

CMS Current Emergencies

See additional COVID-19 updates below:

Skilled Nursing Facilities (SNFs)

CMS is temporarily waiving the following requirements for SNFs:

3-Day Prior Hospitalization Coverage for SNFs

For those individuals who need to be transferred as a result of an emergency related to the COVID-19 virus, Medicare will waive this requirement when the following conditions occur:

Evacuated from a nursing home in the emergency area;
Discharged from a hospital (in the emergency or receiving locations) in order to provide care to more seriously ill patients; OR
Need SNF care as a result of the emergency, regardless of where the individual resided

Renewal of SNF Benefit Period

Medicare beneficiaries who have recently exhausted their SNF benefits may have their SNF coverage renewed without having to start a new benefit period. The 60-day post-discharge wellness requirement for a new 100-day SNF benefit period to begin will be waived.

Additional SNF care related to the COVID-19 virus will be covered without requiring a break in the spell of illness
Individuals who had either begun or were ready to begin the process of ending their spell of illness will receive up to an additional 100 days of SNF Part A coverage

Standard MDS Timeframes Waived

CMS will waive the standard timeframe requirements for Minimum Data Set (MDS) assessments and transmissions, which are normally due at the time of admission, within 14 calendar days after admission or change in condition, and upon discharge/transfer, among others.

Toyon’s Take:

Providers will need to educate their clinical and billing staff on these changes. How quickly will the MACs’ billing systems be ready to accept bills containing these changes? Billing departments may expect to have claims rejected at first and to require additional help to code and resolve claims.

Critical Access Hospitals (CAHs)

CMS is waiving the following requirements for CAHs:

Limitation for the number of beds to 25
Limitation for the average length of stay to 96 hours

Toyon’s Take:

This waiver will allow CAHs to accept COVID-19 patients in rural areas where bed space may be scarce. How quickly can CAHs increase staffing in order to handle an increase in patients?

Acute Care Patients in Excluded Distinct Part Units

CMS is allowing the following changes for housing acute care patients in hospitals:

Hospitals may be allowed to house acute care patients in excluded distinct part units, where appropriate, as a result of this emergency
The patient’s medical record should be annotated to indicate that the acute care patient is being housed on an excluded unit due to the emergency

Excluded Unit Patients in Acute Care Settings

CMS is waiving the following requirements regarding care for excluded unit patient in the acute care settings of hospitals:

Hospitals may be allowed to house excluded distinct part IPF unit patients in acute care settings, as a result of this emergency, and continue to bill for services under the IPF PPS, where the environment is appropriate and conducive to safe care
Similarly, hospitals may be allowed to house excluded distinct part IRF unit patients in acute care settings, as a result of this emergency, and continue to bill for services under the IRF PPS, where the environment is appropriate, and patients continue to receive intensive rehab services
CMS will allow IRFs to exclude patients, who are admitted to the unit as a result of this emergency, from the IRF population for purposes of calculating the 60% threshold that is required for an IRF to maintain its special certified status

Long-Term Care Hospitals (LTCHs)

LTCHs will be allowed to exclude patient stays related to this emergency in order to meet the 25-day average length of stay requirement.

Toyon’s Take:

Providers will need to consider whether or not it is safe to place patients with non-psychiatric diagnoses on IPF units that house more acute psychiatric patients and vice versa.

Presumably, CMS will consider both misplaced acute patients on IRF units and misplaced IRF patients on acute care units when calculating the 60% threshold during this fiscal year. The appropriate coding on the claims will need to be verified in order to identify these patients.

Coverage and Payment Issues

CMS is making the following changes to Medicare beneficiary coverage:

Vaccine: Once developed, the COVID-19 vaccine will be covered in full under Part D
Hospital Stays: Patients with the virus who no longer meet the need for acute inpatient care but are being quarantined in a hospital patient room may not be charged a private room accommodation differential and will not have to pay an additional deductible for the quarantine period
IPPS Payment: Medicare will pay any DRG and outlier payment, including any quarantine time, until discharge, even when the patient no longer meets the need for acute inpatient care
Telehealth: Patients who have an established relationship with their physician or practitioner may have a “virtual check-in” in any healthcare facility as well as their homes, where the communication need not be related to a medical visit within the previous seven days and does not necessarily lead to a medical visit within the next 24 hours. This expansion of services will also allow patients to access their physicians using a wider range of communication, including telephones with audio and video capabilities. In addition, CMS is granting Medicaid waivers to cover broader telehealth services for its beneficiaries.

Toyon’s Take:

If necessary, hospitals should create a new Medicare COVID-19 private room charge in their CDMs to reflect similar charges for both private and semi-private room accommodations, when patients are diagnosed with the virus. Unless the patient is in an ICU room, it is unlikely that the charges from additional days will generate an outlier payment.

Coverage and Payment Issues

CMS is making the following changes to Medicare beneficiary coverage:

Vaccine: Once developed, the COVID-19 vaccine will be covered in full under Part D
Hospital Stays: Patients with the virus who no longer meet the need for acute inpatient care but are being quarantined in a hospital patient room may not be charged a private room accommodation differential and will not have to pay an additional deductible for the quarantine period
IPPS Payment: Medicare will pay any DRG and outlier payment, including any quarantine time, until discharge, even when the patient no longer meets the need for acute inpatient care
Telehealth: Patients who have an established relationship with their physician or practitioner may have a “virtual check-in” in any healthcare facility as well as their homes, where the communication need not be related to a medical visit within the previous seven days and does not necessarily lead to a medical visit within the next 24 hours. This expansion of services will also allow patients to access their physicians using a wider range of communication, including telephones with audio and video capabilities. In addition, CMS is granting Medicaid waivers to cover broader telehealth services for its beneficiaries.

Toyon’s Take:

Provider Enrollment

CMS will be making the following changes to the provider enrollment process:

Waiver of application fee
Waiver of site visits
Postponement of all revalidation actions
Allow licensed providers to render services outside of their state of enrollment
Expedited pending or new applications from providers

Toyon’s Take:

Even though many of the steps in the standard provider enrollment process may be temporarily waived, providers should be prepared for CMS and State Agencies to revisit these applications and perform a more thorough follow-up review, after this emergency has passed. Providers should maintain all documentation related to any provider enrollment action until that follow-up review is conducted should that be necessary.

Medicaid Programs

CMS is allowing states the flexibility to make changes, such as the following examples:

Waive prior authorization requirements for fee-for-service programs
Permit providers located out of state to provide care to another state’s Medicaid enrollees who are impacted by this emergency
Temporarily suspend certain provider enrollment and revalidation requirements
Temporarily waive requirements that physicians and other healthcare professionals be licensed in the state in which they are providing services, so long as they have an equivalent license in another state
Temporarily suspend requirements for certain pre-admission and annual screenings for nursing home residents

States can assess their needs in the Medicaid Response Toolkit.

COVID-19 Testing: HCPCS U0001 / HCPCS U0002

Beginning April 1, providers can bill Medicare and other insurers for COVID-19 testing provided on or after Feb. 4 using the following Healthcare Common Procedure Coding System (HCPCS) codes:

HCPCS U0001 – Medicare will reimburse approximately $36 to allow providers to bill for using CDC’s RT-PCR Diagnostic Test Panel
HCPCS U0002 – Medicare will reimburse approximately $51 for validated, in-house developed COVID-19 diagnostic tests.

Please refer to the link below for COVID-19 Test Pricing by MAC jurisdiction:

https://www.cms.gov/files/document/mac-covid-19-test-pricing.pdf

Other Recently Published Rules

Interoperability and Patient Access Final Rule [CMS-9115-F]

(FR Publish Date TBD)

Fact Sheet Link

Draft Final Rule Link

Improved exchanges for dually eligible patients, which will change from monthly to daily (beginning April 1, 2022)
CMS will begin publicly reporting hospitals and clinicians that may be blocking information, based on their EHR attestations (late 2020)
CMS is modifying provider CoPs to require that electronic event notifications of a patient’s admission, discharge, and/or transfer be sent to healthcare facilities or practitioners in an effort to improve coordination of care (effective 6 months after publication of this Final Rule)

This information was current as of the time it was published.

Other Rules, Transmittals, and Articles Recently Published

May 2, 2019

Inpatient Psych Facility PPS Proposed Rule [CMS-1712-P]
(Display Copy available here 4/18/2019; FR Publish Date 4/23/2019)
Fact Sheet Link Federal Register Link
* Per diem base rate increase from $782.78 to $803.48.
* Elimination of 1-year lag in WIF, aligning it with concurrent IPPS WIF.

Inpatient Rehab Facility PPS Proposed Rule [CMS-1710-P]
(Display Copy available here 4/17/2019; FR Publish Date 4/24/2019)
Fact Sheet Link
Federal Register Link
* Standard payment conversion factor increase from $16,021 to $16,573.
* Elimination of 1-year lag in WIF, aligning it with concurrent IPPS WIF.

Long-Term Care Hospital PPS Proposed Rule [CMS-1716-P]
(Display Copy available here 4/23/2019; FR Publish Date 5/3/2019) – Published as part of the IPPS Acute Care Hospital Proposed Rule
Fact Sheet Link
Federal Register Link
* LTCH-PPS payments expected to increase by 0.9% or $37M.
* Proposal to modify the “Discharge to Community” measure to exclude nursing home residents who already reside in the nursing home.

Skilled Nursing Facility PPS Proposed Rule [CMS-1718-P]
(Display Copy available here 4/19/2019; FR Publish Date 4/25/2019)
Fact Sheet Link
Federal Register Link
* Increase in unadjusted Federal per diem rates of 2.5%.

Supplemental Security Income (SSI) Data for FFY2017 (Trans 2271, CR 11187)
(Publish Date 3/29/2019)

CMS Change in Policy for Accounting of Medicare Crossover Bad Debts (MLN Connects)
(Notice Date 4/4/2019) Click here for a copy of the MLN Connects article from CMS.

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