In response to the COVID-19 crisis, several important updates from CMS and the Department of Health & Human Services were posted over the last weekend. HealthPRO Heritage’s COVID-19 Task Force immediately released a summary about these updates (i.e.: waivers of the 3-day stay & the 60-day break).
Some much-needed perspective and interpretation of what these new changes mean for patients, staff, and your IDT’s processes are captured herein.
For starters, it helps to first understand why these changes were issued now; the waivers for the 3-day stay and the 60-day hold are intended to:
- Free-up hospitals, medical staff, and other resources as the system prepares for a likely increase in COVID-19 related hospitalizations; and
- Protect uninfected SNF patients from having to risk exposure to COVID-19 by being hospitalized; and
- Isolate SNF patients with presumed/confirmed COVID-19 within the SNF to prevent potential spread to hospitals
The Domino Effect
SNFs should keep in mind that these changes will allow for potentially unique situations and mean significant workflow and process-related ramifications, so IDTs should be aware of potential nuances.
Consider, for example, a situation where it may be too risky to send a patient back to the hospital due to concerns related to COVID-19. CMS’s new changes now allow for a patient to skill in place so as long as they qualify (i.e.: are receiving daily skilled care, as outlined by the Medicare Beneficiary Policy Manual, Chapter 8).
In the unfortunate event a SNF patient/resident is confirmed/presumed to have COVID-19, the recent waiver of the 3-day hospital stay, and also 60-day wellness period requirement now allows for the SNF to provide care without having to risk exposure by hospitalizing compromised patients. In this scenario, HealthPRO Heritage advises:
Caring for a patient with COVID-19 will require an abundance of resources in order for a SNF team to prioritize safety, deliver quality care, and take every precaution to keep other residents/patients and staff safe. Consider, for example, the need for following “strict isolation” procedures + the resources that must be deployed to care for a patient/resident in isolation (e.g.: treatments & meals in the room, use of disposable supplies, support for mental/emotional well-being, etc). Keeping these residents safe and engaged will require staff to do everything from tracking temperatures + monitoring lung sounds + watching for signs related to mood changes, etc.
Proper documentation for a patient with COVID-19 will assure that SNFs get appropriately reimbursed for the extensive services and resources needed to assure safety and achieve positive outcomes. As always, documentation should – at least! – include:
- Observations made
- Assessments completed
- Actions taken
- Treatment provided
Coding for a patient with COVID-19 will necessitate:
- Careful review and detailed understanding of factors related to co-morbidities;
- Special actions taken (as with +1 NTA point for “Strict Isolation” & “Infection Control Measures”); and
- Learning how to use “Disaster Related” codes associated with COVID-19-related care. (Note: This “DR” condition code is entered on the UB04’s in boxes 18 thru 28)
- Proper ICD-10 coding of the disease process, whether it is COVID-19 or an associated condition, will help to ensure accurate mapping, reimbursement, and capture for the patient being treated
MORE CONSIDERATIONS and QUESTIONS WORTH ASKING
- When might the IDT consider an IPA while caring for a patient presumed or confirmed with COVID-19?
- How does Respiratory Therapy play a part in caring for a patient presumed or confirmed with COVID-19?
- For guidance on these questions + MORE: Check out The Strategy Academy podcast that accompanies this blog.
Kristi Smith, Vice President of Clinical Strategies, MSPT, RAC-CT
Elisa Bovee, Vice President of Clinical Strategies, MS, OTR/L