The COVID-19 pandemic is hitting skilled nursing facilities (SNFs) hard. Along with the potential health impact on your residents, staff, and families, there have been several regulatory updates issued by CMS after a State of Emergency was declared on March 13th. Here are five things that nurse assessment coordinators (NACs) should know.
New ICD-10 code for COVID-19
The effective date for the new code, which was originally planned for October 1, has been pushed up to April 1. The details and exclusions for the new code, U07.1 COVID-19, can be found in the ICD-10-CM Tabular List of Diseases and Injuries April 1, 2020 Addenda. As with any diagnosis, in order to code COVID-19 in Section I8000 you will need a physician’s diagnosis with supporting laboratory results.
Coding O0100M, Isolation for active infectious disease
In some cases, you may have residents with COVID-19 who meet the criteria to capture isolation on the MDS. This will potentially capture the Extensive Services qualifier for PDPM and RUG-based Medicaid reimbursement. However, make sure that all the criteria are met for this item (see the RAI v. 3.0 Manual on pp. O-5 and O-6). In particular, remember that:
- The isolation is “single-room” – cohorting with another resident who also has COVID-19 does not count.
- The resident must remain in his or her room – all services must be brought into the isolation room.
- If the resident needs to leave the room for a medically necessary reason, the CDC Guideline for Isolation Precautions must be followed.
Relaxation of the MDS submission requirements
As part of the Section 1135 waiver, CMS waived the MDS submission timeframe requirements in 42 CFR 483.20. This waiver allows some breathing room for facilities that need to have all hands on deck caring for their residents with COVID-19 including the MDS team. However, CMS hasn’t yet released any further guidance on this, nor have they specifically addressed Medicare PPS assessments. Our recommendation: keep up to date on your MDSs if you possibly can. Remember that the standard MDS timeframe allows 14 days to complete the MDS after the Assessment Reference Date, and another 14 days after the MDS completion date in Z0500B or the care plan completion date in V0200C2 (RAI v. 3.0 Manual, p. 5-3). Use that time, and only opt for the waived timeframe if you absolutely need it to stay in compliance.
SNF Quality Reporting Program (QRP) reporting requirement exceptions/extensions
CMS has announced that the upcoming data submission deadlines for Q4 2019, as well as data for Q1 and Q2 2020, will be optional. This goes along with the MDS submission waiver above, as well as submitting corrections to MDSs that appear in your “dash report.” Again, our recommendation is to stay on track if you are able to, and make sure that the MDSs you submit are as complete as possible so that any future reporting is accurate.
Infection control also applies to the MDS process
As you are interacting with your residents doing your assessment – resident interviews, observation for swallowing problems, balance assessment etc. – be sure to maintain transmission-based precautions. Consider your resident interview process; are you able to maintain six feet of distance from the resident and still be able to communicate? Assess whether personal protective equipment (PPE) is needed, and refer to your facility’s infection control and PPE conservation policies to make sure that your residents (and you) are protected when you are working with them.
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