On Sept. 8, 2021, CMS updated SE20011 (see p. 13)  regarding Emergency SNF QHS and benefit period requirements under Section 1812(f) of the Social Security Act which were implemented to help restore SNF coverage for patients affected by the emergency. The update clarified the following:

these emergency measures don’t waive or change any other existing requirements for SNF coverage under Part A such as the SNF level of care criteria, which remain in effect under the emergency.”  Using the authority under Section 1812(f) of the Social Security Act, CMS doesn’t require a 3- day prior hospitalization for coverage of a SNF stay, which provides temporary emergency coverage of SNF services (including SNF-level swing-bed services in rural hospitals and CAHs) without a QHS, for those people who experience dislocations, or are otherwise affected by COVID-19. “At the same time, we’re monitoring for any SNF admissions under Section 1812(f) that don’t meet the SNF level of care criteria (which, as noted above, remain in effect during the emergency), and we’ll take appropriate administrative action in any instances that we find. See SNF Billing Reference for more information on SNF eligibility and coverage requirements.” Also, for certain patients who recently exhausted their SNF benefits, the waiver authorizes a one-time renewal of benefits for an added 100 days of Part A SNF coverage without first having to start a new benefit period (this waiver will apply only for those patients who have been delayed or prevented by the emergency itself from commencing or completing the process of ending their current benefit period and renewing their SNF benefits that would have occurred under normal circumstances). For the QHS waiver: • All patients qualify, regardless of whether they’ve SNF benefit days remaining • The patient’s status of being “affected by the emergency” exists nationwide under the current PHE. (You don’t need to verify individual cases.)

 Proactive has noted medical review beginning related to this issue including UPIC activity. Contact our team for a compliance review of supportive documentation related to SNF eligibility and coverage or for assistance in managing medical review or appeals.


Amie Martin OTR/L, CHC, RAC-CT, MJ, Proactive Medical Review

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