CMS Corrects Guidance on Billing SNF Part A Stays for 3-Day Waiver Admissions

COVID-19; Reimbursement
 

The Centers of Medicare and Medicaid Services (CMS) has published updated claim coding guidance related to the use of the DR condition code on claims after the end of the COVID-19 public health emergency (PHE) in its weekly MLNconnects newsletter. This guidance titled, COVID-19: Reporting CR Modifier & DR Condition Code After Public Health Emergency, corrects guidance previously posted on March 16. 

The updated guidance explicitly states that for benefit period and 3-day qualifying hospital stay waivers, skilled nursing facility and swing bed providers should continue to submit condition code DR for Medicare Part A claims for those residents with admission dates before May 12, 2023. This means that the DR condition code would on claims for those residents until they are discharged from Medicare Part A coverage, or their 100-day benefit period is exhausted. The DR condition code should not be used on SNF Part A claims for residents with dates of admission on or after May 12, 2023. Below is the text of the CMS notice.

COVID-19: Reporting CR Modifier & DR Condition Code After Public Health Emergency 
The end of the COVID-19 public health emergency (PHE) is expected to occur on May 11, 2023. Since the CR modifier and DR condition code should only be reported during a PHE when a formal waiver is in place, plan to discontinue using them for claims with dates of service on or after May 12, 2023. 

Skilled Nursing Facility & Swing Bed Providers
Background 
On March 16, the Centers of Medicare and Medicaid Services (CMS) published claim coding guidance related to the use of the DR condition code on claims after the end of the COVID-19 public health emergency (PHE) in their weekly MLNconnects newsletter. In that initial announcement the agency indicated that the DR condition code related to the COVID-19 waivers should not be used on any claims with dates of service on or after May 12, 2023. AHCA immediately requested that CMS reconsider this guidance citing concerns that the Medicare claims processing systems may not be able to correctly identify and pay for SNF claims for residents admitted under a 3-day qualifying hospital stay waiver or starting a spell of illness COVID-19 waiver on or before May 11, 2023, unless providers can continue to append the DR modifier to claims for these individuals. The recent May 30 correction announced by CMS resolves this concern. 
 
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