I know the PHE is set to expire in July. As we continue to admit new patients using the SNF waivers, what will happen if the PHE ends during the patient’s benefit period?
Effective April 21, 2021, HHS Secretary extended the PHE, the new expiration date begin July 20, 2021. According to pg 119 of the CMS COVID-19 FAQ Document, “If a beneficiary has qualified for the special one-time renewal of SNF benefits under the benefit period aspect of the section 1812(f) waiver while the section 1812(f) waiver is in effect, that reserve of 100 additional SNF benefit days would remain available for the beneficiary to draw upon even after the waiver itself has expired.”
Further, HHS Secretary issued a letter to all states in early 2021 outlining the plan for the PHE duration. The HHS Secretary specifically stated: “To assure you of our commitment to the ongoing response, we have determined that the PHE will likely remain in place for the entirety of 2021, and when a decision is made to terminate the declaration or let it expire, HHS will provide states with 60 days’ notice prior to termination.” This means that SNF’s can be assured they will receive a 60-day advance notification of expiration, we can project out 2 months at a time, even if the PHE does not last “the entirety of 2021.”