Throughout the Public Health Emergency (PHE), certain waivers have remained in place including the 3- day Hospital Stay waiver for Skilled Nursing Facility (SNF) Services. The big question has been when to use it for long-term Residents who have been newly diagnosed with COVID-19 – To Skill or Not to Skill? Then if you do skill the Resident what needs to be documented?
The waivers issued during the Public Health Emergency have not changed the requirements for a skilled stay. It is not about the diagnosis. It is whether or not the Resident truly requires skilled care within the SNF. The documentation requirements haven’t changed either.
Per the Medicare Benefit Policy Manual(MBPM), Chapter 8 – Coverage of Extended (SNF) Services Under Hospital Insurance, Section 30
“Care in a SNF is covered if all of the following four factors are met:
* The patient requires skilled nursing services or skilled rehabilitation services, i.e., services that must be performed by or under the supervision of professional or technical personnel (see §§30.2-30.4); are ordered by a physician…;
* The patient requires these skilled services on a daily basis (see §30.6);
* As a practical matter, considering economy and efficiency, the daily skilled services can be provided only on an inpatient basis in a SNF. (See §30.7.); and
* The services delivered are reasonable and necessary for the treatment of a patient’s illness or injury, i.e., are consistent with the nature and severity of the individual’s illness or injury, the individual’s particular medical needs, and accepted standards of medical practice. The services must also be reasonable in terms of duration and quantity.”
Determining the need for skilled care should include an assessment of the Resident to determine if a skilled stay is warranted based on their overall condition – not simply their diagnosis. This will help support the transition to skilled care.
The SNF documentation should then reflect the medically necessary skills provided by nursing and/or therapy. MBPM, Chapter 8, Section 30.2.1 defines skilled services as “those services, furnished pursuant to physician orders, that:
* Require the skills of qualified technical or professional health personnel such as registered nurses, licensed practical(vocational) nurses, physical therapists, occupational therapists, and speech-language pathologists or audiologists; and
* Must be provided directly by or under the general supervision of these skilled nursing or skilled rehabilitation personnel to assure the safety of the patient and to achieve the medically desired result.”
How are you assessing the need to skill or not to skill? Do you still have questions regarding whether to skill or not to skill? Are you concerned your documentation won’t reflect the need to skill?
Stop wondering and start working with a true partner who will help answer these questions and more – contact Trinity Rehab Services. We look forward to exploring opportunities to move forward together.
*The remaining portion of bullet #1 under the four factors for SNF Care states …“and the services are rendered for a condition for which the patient received inpatient hospital services or for a condition that arose while receiving care in a SNF for a condition for which he received inpatient hospital services”; As the 3-daywaiver negates the need for a hospital stay, this portion of the first factor would not apply.