Subacute-care units provide a specialized level of care to medically fragile patients. Subacute patients are individuals who do not need acute care, but who are too ill to be cared for by most skilled-nursing facilities. Frequently, these individuals are ventilator-dependent or require frequent respiratory treatments. While subacute beds are licensed as skilled-nursing beds, they are reimbursed differently and are subject to additional staffing and patient criteria requirements.
CHA provides state and federal representation and advocacy in the legislative and regulatory arenas to improve access to quality, cost-effective subacute-care services.
Subacute-care units provide a specialized level of care to
medically fragile patients. Subacute patients are individuals who
do not need acute care, but who are too ill to be cared for by
most skilled-nursing facilities. Frequently, these individuals
are ventilator-dependent or require frequent respiratory
treatments. While subacute beds are licensed as skilled-nursing
beds, they are reimbursed differently and are subject to
additional staffing and patient criteria requirements.
CHA provides state and federal representation and advocacy in the
legislative and regulatory arenas to improve access to quality,
cost-effective subacute-care services.
The California Department of Public Health has
Facilities Letter (AFL) 20-76, which informs
skilled-nursing facilities and hospitals with swing beds to
use the revised Minimum Data Set (MDS), effective
CDPH has issued several AFLs for post-acute care providers,
AFL 20-72, which waives certain requirements for home
health agencies during the COVID-19 public health emergency.
This includes provisions related to licensing, staffing and
services, and supervision.
AFL 20-73, which provides guidance to skilled-nursing
facilities to support residents’ ability to express their
treatment wishes through proactive advance care planning. The
AFL includes recommendations for all residents, including those
who have tested positive for COVID-19.
AFL 20-74, which provides recommendations for use of
personal protective equipment, cohorting, and staffing for
skilled-nursing facility residents. The AFL includes a chart
with guidance for each category of COVID-19 status, including
COVID-19-positive residents, symptomatic residents awaiting
test results, exposed and non-exposed residents, and new
The Centers for Medicare & Medicaid Services (CMS) has issued
updated guidance for visitation in skilled-nursing facilities
during the pandemic. The revised guidance notes that previous
restrictions, which focused on protecting residents from COVID-19
by limiting visitation, have taken a physical and emotional toll
on residents. It provides reasonable ways that facilities can
safely accommodate in-person visitation to address the
psychosocial needs of their residents.
While CMS notes that skilled-nursing facilities may continue
to restrict visitation (except virtual visits) based on the
county’s positivity rate, the facility’s COVID-19 status, or
other factors, they may not restrict visitation without a
reasonable clinical or safety cause. The new guidance, which is
effective immediately, also provides that communal activities and
dining can occur with alterations to adhere to guidelines to
prevent transmission. Additionally, CMS notes that facilities may
apply to use civil money penalties funds to purchase tents for
outdoor visitation or dividers to create physical barriers and
reduce risk of transmission during in-person visits.
The Centers for Medicare & Medicaid Services (CMS) has posted for
public review draft
specifications for the Skilled-Nursing
Facility (SNF) Healthcare-Associated Infections Requiring
Hospitalizations measure for the SNF Quality Reporting
CDPH has issued
AFL 20-53.3, updating its guidance for testing health care
personnel and residents at skilled-nursing facilities. The
revised AFL clarifies and aligns with the CMS interim final rule
on testing, and Centers for Disease Control and Prevention
guidance and terminology. Among the important updates:
Skilled-nursing facilities without positive COVID-19 cases
are required to test all health care personnel weekly.
Those with a positive COVID-19 case are required to implement
response-driven testing, as described in the AFL.
Use of point-of-care antigen test instruments and associated
Test reporting requirements
The AFL also clarifies policies for testing newly
admitted/readmitted residents and residents previously diagnosed
with COVID-19, and quarantine for newly admitted residents.
The Office of the State Long-Term Care Ombudsman and the
California Long-Term Care Ombudsman Association have developed a
phased re-entry plan for on-site ombudsman visits to
skilled-nursing facilities. The plan was developed in association
recently updated guidance from the California Department of
Public Health (CDPH), which requires facilities to permit the
ombudsman to enter long-term care facilities, regardless of
whether there is a COVID-19 outbreak.
The goal of the re-entry plan is to resume in-person advocacy
activities safely, thoughtfully, and gradually. During the
initial phase of the plan, on-site visits will be scheduled on a
limited and prioritized basis. They will be focused on
investigations that cannot be conducted by virtual communications
and serious physical or sexual abuse and neglect complaints.
Prior to any on-site visits, ombudsman staff will complete
competency training in infection control procedures and personal
protective equipment use and are subject to screening for fever
and symptoms. Additionally, local long-term care ombudsman
programs are working to align testing requirements with
skilled-nursing facilities in their area.
Skilled-nursing facilities are encouraged to contact their local
long-term care ombudsman office for additional information, and
to consider inviting the ombudsman staff to visit their facility.
The Department of Health Care Services (DHCS) has
information on its website about reimbursement rates for
skilled-nursing facility services, including an additional 10%
reimbursement applied to per diem rates effective March 1 during
the COVID-19 public health emergency.
The California Department of Public Health (CDPH) has revised
All Facilities Letter (AFL) 20-22.4, which provides guidance
on limiting transmission of COVID-19 in skilled-nursing
facilities. The AFL updates visitation guidance to require
facilities to permit ombudsmen to enter regardless of whether
there is a COVID-19 outbreak.
Next CDPH Call for Health Care Facilities: Sept. 1, 8-9 a.m.
(PT)Dial: (844) 721-7239 | Passcode: 7993227
Summary of Aug. 25 CDPH Call
CDPH has provided a
summary of its most recent weekly call with health care
The California Department of Public Health (CDPH) has
Facilities Letter (AFL) 20-66, which provides updated
guidance regarding the provision of dialysis services to
residents of skilled-nursing facilities (SNFs).
The Centers for Medicare and Medicaid Services (CMS) has issued
rule for the federal fiscal year 2021 skilled-nursing
facility (SNF) prospective payment system (PPS). In the
final rule, CMS finalizes a 2.2% increase in SNF PPS per diem
rates of 2.2%, modifies ICD-10 code mappings for patient
classification, and makes updates to the SNF
value-based program, the patient driven payment model
case-mix methodology, and the SNF quality reporting
CHA members can now learn about the Centers for Medicare &
Medicaid Services’ (CMS) discharge planning final rule in a
webinar. The 30-minute webinar offers a high-level overview
of the rule and solicits requests for more information and
clarification to inform CHA’s ongoing advocacy with CMS.