Impact of Public Health Emergency (PHE) Expiration on SNFs: How Polaris Can Help

April 19, 2023
April 19, 2023
Polaris Group
April 19, 2023

Polaris Group consultants can help your nursing home teams with clinical and Medicare compliance support.

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May 11th is quickly approaching and many nursing home administrators are wondering what the end of the public health emergency will mean at that time. While full details are not completely known yet, there will certainly be several regulatory changes that administrators, MDS Coordinators, and DONs need to be prepared for.

Expiration of the SNF 3-Day Waiver

Under the 1812(f) waiver, CMS waived the 3-day prior hospitalization for coverage of a skilled nursing facility (SNF) stay during the pandemic. Recently, the Centers for Medicare and Medicaid Services (CMS) clarified that stays that began under the waiver do not need to end on May 12th. Beneficiaries who had stays that began on or before May 11th will receive their full benefit period as long as skilled care is required. However, with this expiration of the PHE, new admissions will be subject to the 3-day prior hospitalization requirement. As such, SNF admissions teams will need to be diligent about ensuring qualifying stays prior to admission. Polaris Group consultants can help your facility establish procedures regarding checking for qualifying stays when potential admissions are being reviewed.

Full Quality Assurance and Performance Improvement (QAPI) Efforts will restart

During the PHE, CMS modified QAPI requirements to focus on infection control and adverse events. Now, with the PHE expiration, SNFs will be required to resume full QAPI meetings covering the broad scope of QAPI issues in a facility. If your facility has not resumed QAPI meetings for issues outside of infection control or adverse events, Polaris Group consultants can assist with re-establishing the policies and procedures for a QAPI that meet the CMS five key elements.

In-service training requirements will change

To alleviate SNF staff burden during the pandemic, CMS modified the nurse aid training requirements which previously required nursing assistants to receive at least 12 hours of in-serving training annually. Following the expiration of the public health emergency, facilities will be required to provide this training beginning in the first full quarter after the declaration of the PHE. Polaris Group consultants are experts on staff training and can develop personalized training programs to assist the needs of your facility. Particularly if nurse educators have been deployed to more resident care facing roles, Polaris consultants can assist your facilities in providing training within regulatory requirements without placing addition time burdens on your team.  

With many upcoming regulatory changes, now is the time to partner with Polaris Group consultants to improve your facility’s operational performance and navigate ongoing CMS changes.

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