Certified long-term care facilities looking to transfer or discharge residents between themselves for the purposes of cohorting do not need additional approval to do so, the Centers for Medicare & Medicaid Services said Monday.
CMS provided new information about transfer and discharging allowances and 1135 waivers in communications Monday. It noted that certified LTC facilities would need approval from a state agency if they want to transfer or discharge a resident to a non-certified location for cohorting purposes.
The memo explains several different transfer scenarios allowed under the waivers. In one example, certified facilities can transfer residents to a non-certified location, but it must be state-approved and residents must be cared for by LTC facility staff.
“Medicare reimbursement remains with the LTC facility caring for patients in the new location,” the agency explained. “This location could be utilized by multiple LTC facilities, providing care with their own staff.”
LeadingAge Director of Nursing Home Quality and Policy Jodi Eyigor Monday shed light on the various transfer scenarios.
“You can transfer residents based on the 1135 [waiver] if you’re cohorting positive residents, or if you’re transferring negative residents and you want to cohort residents who would be under observation status, readmitting from a hospital or readmitting from the community,” she explained.
“You can transfer residents to another certified nursing facility you have an arrangement with, another nursing home in your community. You do not need the higher approval. You do still have to put out the transfer/discharge notice, but the timelines are a little relaxed on that,” she added.
The facility that is going to be housing the resident and providing the care is the facility that bills for that resident, she noted.
“You can transfer to a non-certified location, something that is not formerly [recognized] as a skilled nursing facility [and] is approved as an alternative care site. But this site has to be state-approved. And it can go through that expedited provider enrollment process. The staff go WITH the resident,” Eyigor emphasized.
“That’s an important piece that was kind of missing when the waiver came out to begin with. So If you are transferring a resident from your facility to one of these alternative care sites, you provide the staff at that alternative care site and then you bill because it’s your staff providing care, even though it’s in a different location.”
Transfers to federal/state facilities
A third scenario is transferring COVID-19 residents to federal and state-run facilities staffed with federal or state personnel. This scenario happens if the government issues the order to transfer, such as to a FEMA-run site. In that case, the government is supplying the staff and the originating facility may not bill for the resident because its staff is not providing care.