In March 2020, CMS made a bold but not unprecedented move by releasing Section 1135 Waiver in Response to the COVID-19 Pandemic. The impact on Skilled Nursing Facilities is significant.
The requirement for a 3-day acute care stay for a post-acute SNF stay to be covered is now waived.
SNF coverage also became available again for those whose benefits became exhausted, without a 60-day break.
The intent of these changes was to increase capacity in acute care by making SNF beds available sooner and free up acute care beds for those who need them more.
Looking back almost 9 months, this has been helpful for SNF providers. Even though SNF occupancy as a whole has been down significantly in 2020, SNFs have seen an increase in Medicare Part A days. This coupled with a per diem rate increase thanks to Patient-Driven Payment Model (PDPM) has been helping SNFs stay afloat.
However, will there be ramifications in the form of future Medicare audits?
(Tough question, and not what we want or need to hear right now).
I expect the answer to be “Yes, but probably not soon.”
In years prior to the COVID-19 pandemic, SNFs were faced with an over-abundance of Medicare audits in the form of ADRs, Probe Reviews, RAC audits, ZPIC audits, and more. Those audits primarily focused on intensity of therapy and the overall necessity for therapy. In a PDPM system, the primary reimbursement drivers are in the nursing and non-therapy ancillary categories.
In preparation for future audits, below are a few questions for Skilled Nursing Facility operators to consider:
1. Is isolation accurately coded?
2. Does the daily nursing documentation support skilled care? The 1135 waiver doesn’t waive the need for meeting Medicare’s skilled coverage criteria. Having strong daily skilled nursing documentation has always been and will continue to be the best way to support skilled care.
3. There has been an increase in the capturing and coding of depression. Be certain the supporting documentation exists.
4. In order to capture non-therapy ancillaries, supporting documentation is required.
5. SNFs who are inaccurately coding altered diets in the Speech-Language Pathology (SLP) category could be easy targets in future audits.
The FY 2021 Medicare Final Rule did not include any significant changes to the structure of PDPM, which is good. Someday this will all be over, and audits are likely to reappear. Let’s be prepared when that happens.