The healthcare industry is at the center of the unprecedented disruption and change brought on by the COVID-19 pandemic. The federal and state governments are modifying various rules and requirements to alleviate burdens and enable care including focusing on delivery in alternate care settings such as Skilled Nursing Facilities (SNF), particularly given the high risk nature of patients in those settings. EXL Health has prepared this short brief to help our clients prepare for the impact on SNFs which are unique, as they serve as both healthcare providers and as full-time homes for some of the most vulnerable Americans.

  • Expect increased utilization of SNFs as hospitals become overburdened
  • CMS will now allow use of telehealth to meet provider visit requirements for SNF patients
  • Amidst the pandemic, SNF healthcare personnel might be at risk of contracting and or transmitting COVID-19
  • Patients in SNFs are high risk for severe COVID-19 outcomes, extra measures to limit exposure are in play
  • Impacts from SNF and telehealth payment changes are unclear

COVID-19 Legal & Regulatory Changes - CARES Act & CMS Declarations

The CARES Act increased Medicare reimbursement

  • The CARES Act suspends the 2% Medicare sequester effective May 1st through December 31st, which will provide additional revenue to SNFs

CMS Altered Key Requirements- Drives Increased Utilization of SNF Services

  • CMS waived the required previous 3-day hospitalization before coverage of a SNF stay for those people who experience dislocation, or are otherwise affected by the COVID-19 pandemic
  • CMS authorized renewal of the 100 day SNF benefit for certain Medicare beneficiaries
  • CMS waived the requirement for physician and non-physician practitioners to perform in-person visits for nursing home residents, indicating those can be performed virtually, potentially through video or audio
  • CMS allowed many more visits to be performed via telehealth options

Accelerating Payments

CMS is making efforts to issue payments within seven days of a provider’s request under an accelerated and advance payment request process

  • To qualify for accelerated or advance payments, providers and suppliers must have billed Medicare for claims within 180 days immediately prior to any request
  • Providers in bankruptcy/with outstanding delinquent Medicare overpayments are not eligible for accelerated payments, nor are providers under active medical review or program integrity investigation
  • As of April 8th, CMS indicated it had paid out over $34 billion in such advance payments to all provider types including SNFs

Key Takeaways for Consideration

  • Given the importance of access to care and the need to keep hospital beds open, many health plans have also removed or altered their normal review and authorization processes for SNF services. This will mean both longer patient stays at SNFs as well as an increased volume of SNF admissions
  • The transition to the new PDPM payment model last October poses unique risks, since providers are not used to billing and documenting under the new rubric
  • The CMS & private health plan changes present an opportunity for providers to over-utilize care. Many SNFs are economically fragile which could lead to disruption due to closure, as well as an increased pressure to attempt to overbill and or over document
  • The need for analytics and resources to identify and investigate potential fraud, waste and abuse will be important
  • We would expect some providers to try to represent novel/unapproved technologies as “tele-treatment” for SNF visits
  • As the crisis dissipates, clients should plan for increased utilization review and payment integrity audits

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