Wednesday, May 20, 2020

Guidance on Documentation for Use of COVID-19 SNF Reimbursement Waivers

The CMS waivers also consider requirements that would normally be in place
for providers to receive reimbursement under Medicare or Medicaid. Most
significant were the waiver of the 3-day prior inpatient hospital stay and the 60-
day break in spell-of-illness requirements for SNF Part A benefit eligibility.

Documentation will be critical to demonstrate an organization’s rationale for the
use of the waivers. In a previous update, AHCA/NCAL offered visual flowchart
guidance to help with coverage determinations of these 1135 waivers.
AHCA/NCAL has provided key documentation guidelines for supporting the
employment of these waivers as it is foreseeable that after the emergency
declaration is rescinded, CMS either through the Officer of the Inspector
General (OIG) or through contractors will look to ensure that Medicare dollars
were spent appropriately without fraud, waste and abuse.

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