Key COVID-19 Resources for SNF Therapy Professionals
The resources below have been compiled from CMS.gov specific to the COVID-19 changes impacting SNF therapists.
Please submit any specific questions related to the information to our Just Ask Q&A Forum.
THIS PAGE IS UPDATED AS THE CMS CHANGES OCCUR DURING THE NATIONAL EMERGENCY
LAST UPDATED 7/26/20
If you have questions for CMS or need clarification on any COVID-19 regulation changes, they are accepting emails at: [email protected]
Temporary Regulations Related to COVID-19
7/26/2020: Public Health Emergency Extended Beyond July 25th
On July 25, 2020, the Department of Health and Human Services released a declaration of renewal of the National Public Health Emergency which will be in effect for the next 60 days. This declaration renews those changes that have been made as a result of the initial declaration in January 2020.
This declaration was released from Secretary Alex Azar:
As a result of the continued consequences of Coronavirus Disease 2019 (COVID-19) pandemic, on this date and after consultation with public health officials as necessary, I, Alex M. Azar II, Secretary of Health and Human Services, pursuant to the authority vested in me under section 319 of the Public Health Service Act, do hereby renew, effective July 25, 2020, my January 31, 2020, determination that I previously renewed on April 21, 2020, that a public health emergency exists and has existed since January 27, 2020, nationwide.
Some of the PHE changes that were renewed include:
- Medicare Part A 3 Night Inpatient Stay
- Medicare Part A 60 Day Benefit Period
- MDS Submission Deadlines
- Telehealth for Medicare Part B
- Skilled Maintenance Therapy Provided by PTA’s and C/OTA’s for Part B
7/17/2020: CMS Updates the SE20011 FAQ Document to include:
SNF Part A Telehealth acknowledgement as an option for service model (though not separately billable to Part B)
Clarification regarding the 1135 Waiver for 3 day hospital stay and 60 day spell of wellness
Read all changes HERE , including MDS and billing instructions, claim rejection instructions
View CMS updated FAQ document HERE
6/1/2020: Telehealth Part B Updated Rules
5/27/2020 **BREAKING SNF NEWS**
- CMS released an updated COVID-19 FAQ document for Medicare Part B (Fee For Service) billing. This 71 page document includes NEW INFORMATION confirming institutional providers, including SNF, can provide Part B Telehealth and bill with the appropriate modifier on the UB-04 claim form. Prior to 5/27/2020, only therapists in private practice were permitted to provide and bill for Part B telehealth.
- SEE PAGE 70 OF THE DOCUMENT HERE (New Info Highlighted)
- CMS Document Link https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf
Prior to 5/27/2020
- As of 5/5/20, CMS confirmed that Telehealth and related e-services for the therapy profession apply to therapists in PRIVATE PRACTICE only.
- Institutional settings including SNF Part B were not able to bill for telehealth services.
- CMS also confirmed that in those Private Practice Settings, PTA’s and C/OTA’s could provide the service, as long as the supervision requirements for that setting were maintained.
- Transcripts from the above call on 5/5/20 can be found here: Tuesday May 5, 2020, CMS Office Hours Call (ZIP) : Find the info below in this file
- Page 8: CMS approval for PTA’s and C/OTA’s to provider Part B TeleHealth in PRIVATE PRACTICE. Includes explanation of temporary ok for virtual direct supervision during National Emergency vs direct in suite supervision
- Page 9-10: Discussion and clarification that Therapy TeleHealth is for PRIVATE PRACTICE billing on Professional 1500 claim form and not Institutional Providers (SNF, ORF) billing on UB-04
- On 5/6/20, APTA also confirmed this information HERE
As noted above, the 5/27/2020 FAQ document overrides the existing rules under COVID-19 and SNF therapy is now permitted (temporarily) for Part B residents
YOU CAN ASK CMS ANY QUESTIONS BY SENDING EMAILS TO: [email protected]
REGULATIONS RELEASED 4/30/20 – Press Release Here
NEW – UPDATED CMS LTC GUIDANCE
- Nursing Home Reopening Recommendation FAQs (PDF) (5/18/20)
- Toolkit for States to Mitigate COVID-19 in Nursing Homes (PDF) (5/13/20)
- CMS letter to Nursing Home Facility Management & Staff (PDF) (5/11/20)
- Guidance on Notification Requirements of Confirmed and Suspected COVID-19 Cases Among Nursing Home Residents and Staff (5/6/20)
Telehealth for Part B
- 5/27/2020: CMS released an updated COVID-19 FAQ document for Medicare Part B (Fee For Service) billing. This Document updates the March 15th Waiver Document
- This 71 page document includes NEW INFORMATION confirming institutional providers, including SNF, can provide Part B Telehealth and bill with the appropriate modifier on the UB-04 claim form. Prior to 5/27/2020, only therapists in private practice were permitted to provide and bill for Part B telehealth.
- SEE PAGE 70 OF THE DOCUMENT
- This information replaces prior temporary COVID-19 rules excluding institutional providers from providing Part B telehealth. Prior to 5/27/20, eligible providers included PT, OT and Speech (including assistants) for PRIVATE PRACTICE settings ONLY
Telecommunications / Technology Use When On Site with the Resident
- CMS responded to a question asked by a SNF therapy provider regarding using technology to assist in the assessment of a resident in the SNF. The caller posed the question to CMS to seek guidance if it was acceptable for a therapist who could not be directly in the room with the resident, to use video with a staff person in the room with the resident to gather information needed to make a clinical decision. (ie: if due to COVID, the therapist could not enter the room but was able to see the resident and speak with a staff person in the room via phone).
- CMS responded that using telecommunications to assist in the assessment of a resident was acceptable, and with the therapist ON SITE, this would not meet the definition of telehealth, therefore, should be billed as standard service.
- Link to CMS Audio file and Transcript from 4/8/20 Call – Listen at 38 minutes or read transcript page 23 for RULING APPROVING TELECOMMUNICATIONS FOR THERAPY ASSESSMENT WHEN THERAPIST IS ON SITE AT A SNF
Skilled Maintenance Therapy for Part B
- PT’s and OT’s that created the plan of care are now able to delegate treatments to be provided by PTA’s and C/OTA’s in all Part B settings (includes SNF)
- COVID-19 Medicare Part A and Part B Resources from Waiver 1135
- Essential Employees – Federal Document
- 3 Day Hospital Stay Requirement for Part A – Waiver – CMS Letter
- 60 Day Spell of Wellness Requirement for Part A – Waiver – CMS Letter
- Telehealth, Virtual Check-Ins, E-Visits for Part B
- Article explaining all of the above for therapists – as of 4/9/20
- Please note that on 5/27/20 new rules were released – see top of page.
- Telehealth and E-Visit Resources
- Rules updated by CMS 5/27/20 – See above
- Medicare Telehealth FAQ – Released 3/17/20
- Medicare Telehealth Provider Fact Sheet
- CMS Provider Telehealth Toolkit
- LTC Provider Toolkit (Applies to those that bill on Professional Claim form – ie: Physician services (not therapy)
- CY2020 Final Rule
- How To Find Your Medicare Administrative Contractor (MAC)
- Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency
- CMS CURRENT EMERGENCY HOMEPAGE – Lists all links related to current National Emergency
- CMS.GOV NEWSROOM
- CDC/FEMA/WHITE HOUSE Coronavirus Info
- COVID Facts and General Info with CDC
This is where all CMS documents and updated information is located
Information on this CMS page specific to SNF Therapists can be found in the links below:
- Blanket Waiver Document – See Pages 9-12 for SNF
- CMS Dear Clinician Letter (PDF) (4/7/20) *Note “Clinician” refers to all types of providers
- Guidance memo – Exceptions and Extensions for Quality Reporting and Value-based Purchasing Programs (PDF) (3/27/20)
- Infection Control – Guidance memo – Exceptions and Extensions for Quality Reporting and Value-based Purchasing Programs (PDF) (3/27/20)
- COVID-19 CMS Partner Toolkit Link
- Long-Term Care Nursing Homes Telehealth and Telemedicine Toolkit (PDF) (3/27/20)
- 5/27/20 Updated Release of FAQ Document for Part B Billing
- Key Recommendations to Nursing Homes, State and Local Governments – 4/3/20
- COVID-19 Long-Term Care Facility Guidance – 4/2/20 (PDF)
- Guidance for Infection Control and Prevention of Coronavirus Disease 2019 (COVID-19) in nursing homes (REVISED 3/13/20)
- Nursing Home Five-Star Quality Rating Updates, Nursing Home Staff Counts, and Frequently Asked Questions (4/24/20)
- Guidance for Licensed Independent Freestanding Emergency Departments (EDs) to Participate in Medicare and Medicaid during the COVID-19 Public Health Emergency (4/21/20)
- New Nursing Home Requirements for Notification of Confirmed COVID-19 Among Residents and Staff (PDF) (4/19/20)
- 2019 Novel Coronavirus (COVID-19) Long-Term Care Facility Transfer Scenarios (PDF) (4/13/20)
- CMS is holding multiple Podcasts, Open Door Forums and Office Hours. You can find audio recordings and transcripts on the link in chronological order.
- Office Hours will be help Tuesdays and Thursdays 5 pm EST
- Recordings are posted in 48 hours of presentation