The Centers for Medicare & Medicaid Services (CMS) issued a new QSO Memo on April 13, 2020, “2019 Novel Coronavirus (COVID-19) Long-Term Care Facility Transfer Scenarios” which includes information related to transfer and discharge of residents between facilities for the purposes of cohorting residents based on COVID-19 status. The supplemental information provided includes information related to the April 2, 2020 Guidance that CMS and CDC released for nursing homes, as well as information on the blanket waivers that have been enacted to provide flexibility to long-term care facilities.
There are several scenarios included in the guidance for LTC facilities:
- Two or more certified LTC facilities (SNFs and/or NFs) that transfer patients among facilities to create a COVID-19 facility and a non-COVID-19 facility
- This is allowed under the Blanket Transfer Waiver – no additional approval required.
- The transfer of residents from one or more certified LTC facilities to a non-certified location
- The non-certified location must be state-approved and a place where residents will be cared for by LTC facility staff.
- The transfer of COVID-19 residents to a Federal/State-run facility
- These facilities that are staffed with Federal or State employees are put in place when there are transfers ordered by governmental agencies/orders.
Billing guidelines for each scenario are included for each scenario as well. The QSO Memo states that “in general,” if certified facilities wish to transfer residents between the facilities for the purposes of cohorting, this is allowable under the blanket waivers. State Agency approval is required for situations where certified facilities wish to transfer/discharge residents to non-certified locations.