This is an important finding, as policymakers have long debated what effect altering the three-day stay would have on utilization. Over 15 percent of skilled nursing facility stays were covered in 2020 using the three-day stay waiver. Although it is unknown what the exact cost implications are for the LTCH and inpatient rehabilitation facility waivers, the Congressional Budget Office (CBO) estimated a 10-year scoring implication of $4 billion related to these waivers.įor skilled nursing facilities, CMS waived the requirement that patients must have a three-day qualifying stay to qualify for Medicare reimbursement. Both the Trump administration and Congress recognized this capacity and aided new referral avenues with waiver of the 60-percent and 3-hour rules, allowing inpatient rehabilitation facilities to receive full reimbursement for all patients. LTCHs continue to serve as a “relief valve” for the surge of COVID-19 patients from STACHs, and in certain markets, as primary acute care COVID-19 hospitals.īecause inpatient rehabilitation facilities are required to have a high level of nursing and physician services, they could handle a high level of patient acuity and function as an alternate site for non-COVID patients that needed hospital-level services during the PHE. To further empower LTCHs, Congress authorized waiver of site neutral payment requirements and the 50 percent rule, allowing LTCHs to admit COVID-19 patients and receive maximum reimbursement. In order to give LTCHs maximal flexibility to admit patients, CMS issued a blanket waiver to exclude patient stays from the twenty-five-day average length of stay requirement, which allowed LTCHs to accept COVID-19 patients from STACHs sooner. LTCHs specialize in ventilation care for critically ill patients, making them well-suited to treat COVID-19. Summary Of Medicare Post-Acute Care Waivers The waiver of these post-acute care rules successfully eased overcrowding in STACHs during a period of acute need, but the question remains as to whether these waivers should be made permanent. Home health agencies and inpatient rehabilitation facilities served a similar role for non-COVID-19 patients, where non-COVID-19 discharges increased 4.5 percent for home health agencies and 2 percent for inpatient rehabilitation facilities from 2019 to 2020. Relative to Medicare beneficiaries without COVID-19 in 2020, those with COVID-19 were more than twice as likely to be discharged from the STACH to a long-term care hospital (LTCH) and 66 percent more likely to be discharged to a skilled nursing facility. ![]() The waivers have had their intended effect. Note: All waivers were implemented with a retroactive start date of March 1, 2020. 116-136” were finalized in the Coronavirus Aid, Relief, and Economic Security Act of 2020, “Blanket Waiver” were finalized on the Centers for Medicare & Medicaid’s website, and “85 FR 27550 was finalized through notice and comment rulemaking. Exhibit 1: Medicare Post-Acute Care COVID-19 Payment and Coverage Waivers Both Congress and the executive branch intended for waiver policies to be time-limited, as their expiration is tied to the end of the public health emergency (PHE) declaration. These waivers led to rapid changes in long-established post-discharge referral patterns. During the pandemic, however, waivers of these rules allowed Medicare post-acute providers to serve as alternate settings for hospitalized patients to alleviate surges in patient volume occurring in STACHs (see Exhibit 1). Prior to the pandemic, rules were in place to ensure systematic and consistent selection of patients for discharge to these settings. One possible approach to ease overcrowding in STACHs is to facilitate discharge to post-acute care (PAC) settings. ![]() ![]() STACHs have had to find alternative external placement venues to treat acute and critically ill patients during the pandemic. Nearly half of STACHs averaged a daily occupancy of 85 percent or higher during the pandemic, operating well above traditional capacity. As of October 29, 2021, over 1.3 million Medicare beneficiaries were hospitalized in short-term acute care hospitals (STACHs) for COVID-19 infection and complications. Throughout the ongoing COVID-19 pandemic, hospitals have experienced an influx of COVID-19 patients.
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