Below is important information provided by AHCA regarding the application of 1812(f) waiver provisions:

MEDICARE Part A FFS

  1. Goal of the Section 1812(f) Waiver is to free up as many hospital beds as possible, nationwide.
  2. Therefore, the waiver is nationwide and applies to all hospitals and all SNFs regardless of whether there is COVID present in the hospital or not.  So, this is blanket and broad-based.
  3. Parameters that remain in place are:
    • Patients must continue to meet the criteria for skilled care located in the Medicare Benefit Policy Manual Chapter 8 – Coverage of Extended Care (SNF) Services Under Hospital Insurance located at https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c08pdf.pdf .  It is criteria this continues to be documented.
    • Long-Stay patients may be converted to Part A stays as long-stays as long as there is clinical evidence to support conversion to Part A. I specifically described the scenario of just converting long-stay folks to Part A.  The response was – if the patient meets the skilled care criteria noted above, they can be converted to Part A with no hospital stay.
  4. In regard to payment:
    • Timeframe:  The waiver is retroactive to March 1, 2020 and is in place for 60 days with the option for renewal as needed; and
    • Billing:  In terms of claims, to ensure payment and so CMS may track these stays,  the “DR” condition code should be used by institutional providers (but not by non-institutional providers such as physicians and other suppliers) in all billing situations related to a declared emergency/disaster. The “DR” condition code is intended for use by providers (but not by physicians and other suppliers) in billing situations related to a declared emergency/disaster.

If you have questions regarding this information, text us at 856-351-5605.