Below is important information provided by AHCA regarding the application of 1812(f) waiver provisions:
MEDICARE Part A FFS
- Goal of the Section 1812(f) Waiver is to free up as many hospital beds as possible, nationwide.
- Therefore, the waiver is nationwide and applies to all hospitals and all SNFs regardless of whether there is COVID present in the hospital or not. So, this is blanket and broad-based.
- Parameters that remain in place are:
- Patients must continue to meet the criteria for skilled care located in the Medicare Benefit Policy Manual Chapter 8 – Coverage of Extended Care (SNF) Services Under Hospital Insurance located at https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c08pdf.pdf . It is criteria this continues to be documented.
- Long-Stay patients may be converted to Part A stays as long-stays as long as there is clinical evidence to support conversion to Part A. I specifically described the scenario of just converting long-stay folks to Part A. The response was – if the patient meets the skilled care criteria noted above, they can be converted to Part A with no hospital stay.
- In regard to payment:
- Timeframe: The waiver is retroactive to March 1, 2020 and is in place for 60 days with the option for renewal as needed; and
- Billing: In terms of claims, to ensure payment and so CMS may track these stays, the “DR” condition code should be used by institutional providers (but not by non-institutional providers such as physicians and other suppliers) in all billing situations related to a declared emergency/disaster. The “DR” condition code is intended for use by providers (but not by physicians and other suppliers) in billing situations related to a declared emergency/disaster.
If you have questions regarding this information, text us at 856-351-5605.