With so many waivers and flexibilities being released by CMS in response to the COVID-19 pandemic, keeping current with those that impact your provider setting can be challenging. Sometimes those that impact you might be designed for another setting altogether!
The Centers for Medicare and Medicaid (CMS) can authorize waivers when the President declares a national emergency and the Secretary of Health and Human Services declares a public health emergency. These steps have been taken, thus enabling CMS to issue waivers.
CMS Waivers – A 4-Pronged Approach
For the current pandemic, CMS uses waivers to support a 4-pronged approach:
1. Increase hospital capacity
- e.g., Hospital without Walls concept allows non-certified beds to be used for Medicare patients
2. Expand workforce
- e.g., Licensed professionals can practice across state lines
3. Emphasize patients over paperwork
- e.g., Relaxing documentation requirements like timing and delivery of discharge documents
4. Support telehealth and medicine
- e.g., Expanding use outside of rural areas or outside medical facilities
SNF 3-Day Waiver
One waiver that impacts Skilled Nursing Facilities (SNFs) also has direct impact on Hospital systems. Since it addresses moving residents to SNF level of care, it falls under the first prong: Increase hospital capacity.
Referred to as the SNF 3 day waiver, this waiver allows Medicare beneficiaries to access their Part A SNF benefit without having the required 3 overnights in an acute care hospital. The beneficiary still needs to have a skilled need that is medically reasonable and necessary, but no longer requires admission to the hospital to qualify.
Implications for Hospitals
What that means to hospitals is that Medicare A patients that come to the Emergency Department can be directly sent to a Medicare certified SNF and be eligible to access Medicare for their skilled nursing benefit. If a beneficiary is hospitalized overnight only, or just for a couple of days, they can also be admitted to the SNF.
As you work with your local SNFs to address this pandemic, review the current waivers and flexibilities available on the CMS Current Emergency site for both your workplaces. Use them to improve your collaboration during these challenging times. We all do better when we work together.
Check out the video below featuring Senior Healthcare Specialist Maria Arellano explaining the 1135 (3 Day) Waiver.
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