We have a patient nearing the end of their 100 Part A days, but now he is COVID+. Will we need to have 1 non-skilled day in order to elect the benefit period waiver?



In November, CMS released an update to the MLN Matters Number (SE20011 Revised) for Medicare Fee-for-Service (FFS) Response to the Public Health Emergency on the Coronavirus (COVID-19). This revision clarifies billing instructions for the same spell of illness beyond 100 days:

To bill for the benefit period waiver:

        • Submit a final discharge claim on day 101 with patient status 01, discharge to home
        • Readmit the beneficiary to start the benefit period waiver.

For ALL admissions under the benefit period waiver (within the same spell of illness)

        • Complete a 5-day PPS Assessment. (The interrupted stay policy does not apply.)
        • Follow all SNF Patient Driven Payment Model (PDPM) assessment rules.
        • Include the HIPPS code derived from the new 5-day assessment on the claim.
        • The variable per diem schedule begins from Day 1.

For ALL SNF benefit period waiver claims, include the following (within the same spell of illness):

        • Condition code DR – identifies the claims as related to the PHE
        • Condition code 57 (readmission) – this will bypass edits related to the 3-day stay being within 30 days
        • COVID100 in the remarks – this identifies the claim as a benefit period waiver request.

Note: Providers may utilize the additional 100 SNF benefit days at any time within the same spell of illness. Claims must contain the above coding for ALL benefit period waiver claims.


Blog by Stacy Baker, OTR/L, CHC, RAC-CT, Proactive Medical Review

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