In response to recent CMS announcements regarding COVID-19, Team TSI has instituted additional coding alerts that are designed to inform providers to potential issues related to COVID-19 and updated CMS guidelines or waivers that may have an impact on MDS coding as well as resident care and services. These alerts are in no way meant to suggest or imply a change in coding is warranted; simply to alert providers to review the most recent CMS guidelines and waivers that may be in effect.

In response to the temporary waiver of the 3-day prior hospitalization requirement for coverage of a skilled nursing facility stay:

• The assessment indicates that this is an entry record and that the resident has a Medicare number (A0600B), but there is no coding to indicate the start of a Medicare A stay (A2400A). Please review the most recent CMS guidelines in response to COVID-19 and any temporary waivers to evaluate if the resident meets the conditions of the waiver to participate in Medicare A.

In response to the temporary waiver of beneficiaries who have recently exhausted their SNF benefits (spell of illness):

• The MDS has been coded as a SNF Part A PPS Discharge Assessment with the resident remaining in the facility. If this is in response to benefits exhaustions (i.e., 100 days) but resident continues to receive skilled services, please review the most recent CMS guidelines in response to COVID-19 and any temporary waivers to evaluate if the resident meets the conditions of the waiver to participate in Medicare A.

In response to the newest recommendations from CMS to reduce risk of transmission, specifically directed at cancelling group activities:

• The MDS has been coded as the resident having received Group and/or Concurrent Therapy (O0400A, B or C) in the last 7 days. Please review the most recent CMS guidelines in response to COVID-19 for delivery of therapy services.

In response to an MDS indicating an active Coronavirus infection where isolation has not been coded:

• Resident has been coded for Coronavirus (B97.29) in Section I, but has not been coded for isolation for active infections disease (O0100M2). Consider screening for isolation and ensuring care plan and proper precautions are in place in accordance with the most recent CMS Guidelines in response to COVID-19 and ensure coding is accurate.

Team TSI will continue to closely monitor recommendations coming from the CDC as well as transmittals and guidance issued by CMS and if appropriate, develop additional coding alerts that may assist a provider in identifying potential issues or opportunities and responding as appropriate.

Team TSI remains committed to serving those who serve others and we thank you for continuing to place your trust in us. Please feel free to reach out with any questions or specific needs related to COVID-19 and continued CMS communications.

Update 1: New COVID-19-Related Alerts

The following new COVID-19-related alerts have been added to the MDS Scrubber.

In response to indications of active COVID-19 diagnosis in the absence of Oxygen therapy being provided:

• COVID-19: Consider that an active diagnosis of COVID-19 has been indicated (I0020B or I8000), but oxygen use while a resident is not coded (O0100C2). Please verify coding to ensure accuracy.

In response to the COVID-19 official coding criteria for Respiratory conditions directly related to COVID-19:

• COVID-19: Consider that an active diagnosis of COVID-19 has been indicated (I0020B or I8000), but potential associated conditions such as Pneumonia (I2000; J12.89), Acute Bronchitis (J20.8), Lower Respiratory Infection (J22) or ARDS (J80) were not indicated (I8000). Please validate diagnosis for the potential presence of these conditions and verify coding to ensure accuracy.

In consideration of current residents that may contract COVID-19 and subsequently receive skilled services secondary to the infection, but are not currently skilled under Medicare A (relevant to the waiver of the 3 day hospital stay):

• COVID-19: Consider that the MDS is coded as having an active COVID-19 infection (I8000). If the resident is receiving skilled services in response to COVID-19, please review the most recent CMS guidelines in response to COVID-19 and any temporary waivers to evaluate if the resident meets the conditions of the waiver to participate in Medicare A.

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