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 CMS Updates SNF Billing Guidance Related to Three-Day Stay, Spell-of-Illness Waivers

The Centers for Medicare & Medicaid Services (CMS) on June 26 updated skilled nursing facility (SNF) billing guidance related to Medicare beneficiaries receiving care when a SNF utilizes the COVID-19 public health emergency (PHE) three-day stay and spell-of-illness waivers.

According to an update by the American Health Care Association/National Center for Assisted Living (AHCA/NCAL), the new guidance was posted in a revised MLN Matters article SE20011 under the heading “Skilled Nursing Facility (SNF) Benefit Period Waiver—Provider Information” (pages 9-13).

This section includes a summary of the waivers, examples of how beneficiaries could qualify for the qualifying hospital stay (QHS) three-day stay waiver and the spell-of-illness benefit period waiver.

Most importantly, AHCA/NCAL said, CMS included detailed guidance for documentation, completing Minimum Data Set assessments and entering claims data needed in order to permit processing of claims using the waivers.

CMS notes in the update that Medicare Administrative Contractors will be required to manually process waiver claims but must “make every effort to ensure timely payment” within the 14-day payment floor. Finally, CMS provided guidance related to handling claims previously submitted that need to be addressed to bypass existing edits.

“We really appreciate that CMS was able to respond to our concerns and provide the detailed claims guidance for these waivers so their claims can be paid in a timely manner,” says Daniel Ciolek, AHCA associate vice president of therapy advocacy.

AHCA/NCAL said it highly recommends that providers review the guidance and share with clinical and billing staff. It added that CMS is expected to post frequently asked questions associated with its updated billing guidance soon.

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