COVID-19: Protecting our Most Vulnerable – CMS’ announcements, 3-day waiver and more…

President Trump’s National Emergency Declaration, Friday the 13th provided clarification surrounding dramatic changes to our SNF setting of care. In an effort to combat and contain the spread of COVID-19, CMS waived the 3 day prior hospitalization requirement [Section 1812 (f) of the Social Security Act] for coverage of a skilled nursing facility (SNF) stay providing temporary emergency coverage of SNF services without a qualifying hospital stay.

A Few Key Points

surrounding this waiver as well as other measures CMS released Friday in efforts to protect our most vulnerable of populations:

Visitation Restrictions:

All visitors, volunteers and non- essential health care personnel are now restricted. End of life visitation being an exception handled on a case-by-case situation

Cancellation of all group activities and communal dining:

Rehab Delivery Strategies / Reminders:

  • thorough hand washing and disinfecting of equipment between each resident (no shared theraputty!!!)

  • safe distancing of 6 feet between residents if concurrent or gym setting treatments are being delivered

  • one on one therapy sessions

  • treatment in patient rooms for anyone at highest of risk or presence of respiratory infection symptoms (fever, cough, shortness of breath, sore throat)

  • constant assessment of rehab team members for signs and symptoms of potential infection

  • FOLLOW provider, state and federal guidelines

3 Day Waiver: Freeing hospital beds and containing potential risk to our patients and others

Criteria - must meet Medicare Manual Skilled Services Definitions (not limited to COVID-19 Dx – follow CMS releases closely for additional details)

Opens potential for Direct Admissions from Community - Ex: ED direct admit to SNF if established skilled need, or recent DC to community has a decline warranting skilled care that is able to be met in SNF vs Acute Hosp with physician guidance

Renewed SNF Coverage without having to start a new benefit period for ‘certain beneficiaries who recently exhausted their SNF benefits’


Physicians determination of daily skilled care being medically necessary and indicated

  • Complexity and frequency of needs for skilled services require in-patient setting.

- Requires multiple skilled treatments daily

- Need for daily skilled services exceeds care available at lesser levels such as HH

Services provided daily by or under the supervision of skilled nursing or therapy staff

  • Observation and Management of Care Plan (Ex: fever, cough, SOB, sore throat requiring close skilled monitoring and assessment)

  • EX skilled services: IV fluids, IV meds, Respiratory Treatments

Above and additional points are included in the press releases below from Friday the 13th linked below:

Let's Get to the Point:

Protect Yourself and Our Vulnerable Population!