CMS Updates Medicare COVID-19 Billing Guidance

On September 8, 2021, the Centers for Medicare and Medicaid Services (CMS) Updated MLN Matters Article SE20011 titled Medicare FFS Response to the PHE on COVID-19. In the billing guidance CMS DID NOT change the longstanding blanket 3-day qualifying stay or spell-of-illness waivers for beneficiary eligibility for SNF Part A coverage.

In the CMS SE20011 guidance update, CMS added emphasis that all other coverage requirements including need for skilled level of care remain (page 13). This is consistent with prior CMS and AHCA guidance. Additionally, CMS now notes that contractors will be monitoring and auditing as needed to verify that the need and delivery of a skilled level of care was present.