Ask Proactive – 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?

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?

A:

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.