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Skilled Nursing Facility (SNF): Skilled and Subacute Levels of Care
MA02.004a

Policy

This policy uses coverage criteria developed solely based on applicable Medicare statutes, regulations, NCDs, LCDs, CMS manuals and other applicable Medicare coverage documents.​


MEDICALLY NECESSARY


SKILLED NURSING FACILITY: SKILLED LEVEL OF CARE

Admission to a skilled nursing facility (SNF) for a skilled level of care is considered medically necessary and, therefore, covered when ALL of the following criteria are met:

  • The individual is medically stable.
  • The individual requires skilled nursing or skilled therapy services, which must be ordered by an eligible professional provider (i.e., physician, nurse practitioner, physician assistant), and requires the skills, knowledge, and judgment of skilled nursing or skilled therapy professionals, who must perform or supervise the provision of these services.
  • The individual requires these skilled services on a daily basis.
  • The services​, as a practical matter,​​ cannot be provided or are unavailable in a less-intensive setting, such as home, office, outpatient, or long-term care facility with intermittent skilled services.
  • The frequency, quantity, and intensity of these services are necessary for the management of the individual's diagnosis, taking into consideration their medical needs and accepted standards of medical practice.
  • The individual also meets the criteria listed in the Skilled Therapy Services and/or Skilled Nursing Services sections.

Note: In order for a service to be considered skilled, the service, due to its inherent complexity, is such that it can only be performed safely and/or effectively by or under the supervision of professional nursing or skilled therapy professional.

Skilled Level of Care ​for the Provision of Skilled Therapy Services
 
In addition to the above criteria listed for SNF, skilled level of care ​for the provision of skilled therapy services ​to improve or maintain, or to prevent or slow further deterioration of, the member's condition ​are considered medically necessary and, therefore, covered when ALL of the following criteria are met:   

Frequency and Intensity of Services:

  • The individual requires skilled therapy at a frequency and intensity of, at a minimum, 1 to 2 hours per day, 5 days per week.

Complexity of Services:

  • The services are of a level of complexity and sophistication​, or the condition of the individual ​​is such that ​the needed services can be safely and effectively performed ONLY by a therapist (or under the direct supervision of a therapist for physical or occupational therapy).  

Participation:

  • The individual is willing and able to actively participate in therapy. 
​​ Mobility:
  • The individual requires at least minimum assistance (functional level) for at least one of the following:
    • Transfers
    • Ambulation for household distances (if <50 feet) and/or, if nonambulatory, wheelchair use at household distances (if <50 feet)
  • Gait training and teaching of prosthesis care for individuals with a recent amputation 

Functional Assessment and Goals:

  • An assessment of the individual's clinical condition was considered in developing goals of therapy that are reasonable and based on the individual's clinical condition.​
  • The individualized assessment demonstrates that the specialized skills, knowledge, and judgement of a qualified therapist are necessary for the creation and/or performance of the skilled therapy plan
  • There is an expectation that one of the following will be met: 
    • ​the individual's functional capabilities will improve significantly in a reasonable and predictable period of time
    • Skilled therapy services require the specialized skills, knowledge, and judgment of a qualified therapist for the creation and/or performance of a safe and effective maintenance program. 
  • Objective documentation of the most recent functional status and measured progress toward goals must be provided.
  • The services must be considered by accepted standards of medical practice to be specific and effective treatment for the individual's condition. ​

Skilled Level of Care for the Provision of ​Skilled Nursing Services


In addition to the above criteria listed for SNF, skilled level of care for the provision of skilled nursing services to improve or maintain, or to prevent or slow further deterioration of, the member's condition is considered medically necessary and, therefore, covered when all of the following criteria are met:  


Frequency and Intensity of Services:

  • Skilled nursing services must be needed and provided on a “daily basis," i.e., on essentially a 7-days-a-week basis.

Complexity

  • The services are of a level of complexity and sophistication, or the condition of the individual is such that the needed services can be safely and effectively performed ONLY by a qualified licensed nurse.  ​
  • When skilled nursing services are specifically needed for the sole purpose of monitoring and/or evaluating an individual's medical condition, it must be likely for the individual to require modification of treatment or initiation of additional medical procedures and are considered medically necessary until the individual's condition is essentially stabilized.
Examples of Skilled Nursing Services include 
  • Treatment of decubitus ulcers or wounds, whose measurements demonstrate a severity rated at a stage three or worse and require complex wound care.  Examples of complex wound care include:
    • weekly assessments required by a wound care specialist for consideration of sharp debridement of necrotic tissue
    • treatment of nutritional impairment (albumin <3.0) with nutritional supplements or enteral supplemental tube feedings for profound malnutrition
    • stage IV with bone involvement (osteomyelitis) and debridement of infected bone requiring 6 to 8 weeks of systemic antibiotics guided by bone cultures
    • ulceration near anus with consideration of fecal diversion​
  • Initiation of nasogastric tube feeding, gastrostomy, and jejunostomy feeding, or when documented complications exist. Enteral feedings must comprise at least 26% of daily calorie requirements and provide at least 501 mL of fluid per day.
  • Administration of intravenous (IV) injection drugs in either of the following situations:
    • Two or more medications are administered daily
    • Medications administered two or more times per 24 hours​​

SKILLED NURSING FACILITY: SUBACUTE LEVEL OF CARE
 In addition to the above criteria​ for SNF, admission to a SNF for a subacute level of care is considered medically necessary and, therefore, covered when ALL of the following criteria are met: 

  • The individual requires skilled nursing services at least 4 hours per day ​on a daily basis and/or 2 to 3 hours per day of skilled therapy (physical therapy and/or occupational therapy) on at least 5 days per week.
  • The individual's medical condition is complex, requiring more than once-weekly professional provider (e.g., professional provider or physical therapist) assessment, intervention, care plan update.
  • The individual must also meet the criteria listed in the Subacute Level of Care Nursing Services and/or Subacute Level of Care Skilled Therapy Services sections.​
​​Subacute Level of Care for the Provision of ​​Skilled Therapy Services​


In addition to the above criteria for SNF, subacute level of care for the provision of skilled therapy services is considered medically necessary and, therefore, covered when the following criteria​ are met:

  • The individual ​requires skilled therapy services for 2 to 3 hours per day at least 5 days per week.​

Subacute Level of Care for the Provision of Skilled Nursing Services​


In addition to meeting the above​ criteria for SNF, subacute level of care for the provision of skilled nursing services is considered medically necessary and, therefore, covered for the following conditions​​/medical needs:

  • ​Administration of ​IV injection drugs in either of the following situations:
    • ​Two or more medications are administered daily (there must be at least one other required skilled service)
    • Medications administered greater than three times per 24 hours​
  • Respiratory care for the following:
    • Mechanical ventilation management/weaning
    • High-flow oxygen management
    • ​New oxygen therapy management requiring monitoring and frequent adjustments (there must be at least one other required skilled service)
  • Wound care for the following:
    • Postsurgical infected wounds requiring IV antibiotics and complex wound care
    • ​Fistula drain management
  • ​Management of chest tubes, nephrostomy tubes, suprapubic catheters, rectal tubes, Dobhoff tubes
  • Daily lab testing requiring frequent IV medication adjustments (there must be at least one other required skilled service)
  • Management of total parenteral nutrition (initial 7 days)
  • Pain management with the following:
    • ​​​Requires medication management (with adjustments), physical therapy, and/or occupational therapy

CONTINUED STAY: SKILLED NURSING FACILITY

Continued stay in an SNF is considered medically necessary and is therefore covered for an individual that continues to demonstrate the need for skilled services as described above or has a condition expected to be of a short-term nature that makes discharge unsafe when care cannot be provided at a lower level of care.​


NOT MEDICALLY NECESSARY


Admission​ or continued stay in a SNF for skilled or subacute levels of care for the provision of skilled therapy services and/or skilled nursing services is considered not medically necessary and, therefore, not covered for conditions such as, but not limited to, the following because the available published peer-reviewed literature does not support its use in the treatment of illness or injury:

  • Individual refuses or is unable to participate in therapy and there are no other skilled needs.
  • Individual no longer requires frequent adjustments of oxygen therapy or complex medications.
  • ​Individual's maintenance care n​eeds can be addressed safely and effectively through the use of nonskilled individuals.

NOT COVERED


CUSTODIAL CARE  
Custodial care is care provided primarily to assist the individual in meeting their activities of daily living (ADLs)​​ and which is not primarily provided for its therapeutic value in the treatment of an illness, disease, bodily injury, or condition. Custodial care also includes health care–related services that do not require the skills of a licensed professional provider. Custodial care is not covered by the Company because it is a service not covered by Medicare. Therefore, it is not eligible for reimbursement consideration.


Examples of custodial care that assists the individual in their ADLs include:  

  • ​Wa​​lking 
  • Getting in and out of bed
  • Preparing meals or special diets
  • Feeding
  • Toileting
  • Bathing
  • Dressing

The following are examples of health care services that generally do not require the skills of a licensed professional once training has been received by a skilled professional. These services can then be safely and effectively performed by nonmedical individuals unless rendered under certain circumstances where there are special medical complications in which skilled nursing or skilled therapy professionals are required to perform or supervise it or to observe the individual. In these cases, the complications and special services involved must be documented by professional providers' orders and notes as well as nursing or therapy notes.  

  • Subcutaneous injections alone, including insulin injections alone (stable dose) in an individual with diabetes
  • Administration or supervision of the administration of routine medications that are typically self-administered (such as but not limited to routine oral medications, eye drops, nebulizers, or ointments).
  • General maintenance care of colostomy and ileostomy
  • Routine administration of enteral feeding through a tube (nasogastric, gastrostomy, jejunostomy, or gastrojejunostomy) 
  • Routine services to maintain satisfactory functioning of indwelling bladder catheters (this would include emptying and cleaning containers and clamping the tubing)
  • Straight catheterization using a clean but nonsterile catheterization technique 
  • Dressing changes for uninfected postoperative wounds or chronic conditions
  • Prophylactic and palliative skin care, including bathing and application of creams, or treatment of minor skin problems
  • Routine care for incontinence, including use of diapers and protective sheets
  • General maintenance care in connection with a plaster cast (skilled supervision or observation may be required where the individual has a pre-existing skin or circulatory condition or requires adjustment of traction)
  • Routine care in connection with braces and similar devices​
  • Use of heat as a palliative and comfort measure, such as whirlpool or steam pack
  • Periodic turning and positioning in bed
  • General supervision of exercises, which have been taught to the individual and the performance of repetitious exercises that do not require skilled therapy professionals for their performance. (This includes the actual carrying out of maintenance programs where the performances of repetitive exercises that may be required to maintain function do not necessitate a need for the involvement and services of skilled therapy professionals. It also includes the carrying out of repetitive exercises to improve gait, maintain strength or endurance; passive exercises to maintain range of motion in paralyzed extremities that are not related to a specific loss of function; and assistive walking.)

REQUIRED DOCUMENTATION


The individual's medical record must reflect the medical necessity for the care provided. These medical records may include but are not limited to: records from the professional provider's office, hospital, nursing home, home health agencies, therapies, and test reports.


The Company may conduct reviews and audits of services to our members, regardless of the participation status of the provider. All documentation is to be available to the Company upon request. Failure to produce the requested information may result in a denial for the service.


SNF care for skilled and subacute level of services: there must be documentation of the complexity of the service to be performed and the documentation must indicate that the services are appropriate in terms of duration and quantity, and that the services promote the documented therapeutic goals.


Recent (within the past 24 hours) documentation of the individual's condition must be provided and must include the following:

  • Baseline functional status
  • Current functional status from all therapies given
  • Recent measured progress toward goals
  • Rehabilitation potential
  • Comorbid conditions
  • Barriers to progress​

Guidelines

BENEFIT APPLICATION

Subject to the terms and conditions of the applicable Evidence of Coverage, a skilled nursing facility (SNF) care for skilled and subacute levels of care are covered under the medical benefits of the Company’s Medicare Advantage products when the medical necessity criteria listed in this medical policy are met.

However, services that are identified in this policy as not medically necessary are not eligible for coverage or reimbursement by the Company.

PRESSURE ULCER STAGING

Pressure Ulcer Staging
Stage I Intact skin with non-blanchable redness of a localized area, usually over a bony prominence. Darkly pigmented skin may not have visible blanching; its color may differ from the surrounding area.
Stage II Partial thickness loss of dermis presenting as a shallow open ulcer with a red/pink wound bed, without slough. May also present as an intact or open/ruptured serum filled blister.
Stage III Full thickness skin loss. Subcutaneous fat may be visible but bone, tendon or muscle are not exposed. Slough may be present but does not obscure the depth of tissue loss. May include undermining/tunneling.
Stage IV Full thickness skin loss with exposed bone, tendon or muscle. Slough or eschar may be present on some parts of the wound bed. Often include undermining and tunneling.
Unstageable​ Full thickness tissue loss in which the base of the ulcer is covered by slough (yellow, tan, gray, green or brown) and/or eschar (tan, brown or black) in the wound bed.
(Suspected Deep) Tissue Injury Purple or maroon localized area of discolored intact skin or blood-filled blister due to damage of underlying soft tissue from pressure and/or shear. The area may be preceded by tissue that is painful, firm, mushy, boggy, warmer or cooler as compared to adjacent tissue.

National Pressure Ulcer Advisory Panel (NPUAP) February 2007.

DESCRIPTION OF THE LEVELS OF FUNCTION AND THEIR SCORES


INDEPENDENT
Another person is not required for the activity (NO HELPER).​​

7- Complete IndependenceThe patient safely performs all the tasks described as making up the activity within a reasonable amount of time, and does so without modification, assistive devices, or aids.
6- Modified IndependenceOne or more of the following may be true: the activity requires an assistive device or aid, the activity takes more than reasonable time, or the activity involves safety (risk) considerations.
DEPENDENTPatient requires another person for either supervision or physical assistance in order to perform the activity, or it is not performed (REQUIRES HELPER).
Modified DependenceThe patient expends half (50%) or more of the effort. The levels of assistance required are defined below.
5- Supervision or SetupThe patient requires no more help than standby, cuing, or coaxing, without physical contact; alternately, the helper sets up needed items or applies orthoses or assistive/adaptive devices.
4- Minimal Contact AssistanceThe patient requires no more help than touching, and expends 75% or more of the effort.
3- Moderate AssistanceThe patient requires more help than touching, or expends between 50 and 74% of the effort.
Complete Dependence:The patient expends less than half (less than 50%) of the effort. Maximal or total assistance is required. The levels of assistance required are defined below.
2- Maximal AssistanceThe patient expends between 25% to 49% of the effort.
1- Total AssistanceThe patient expends less than 25% of the effort.
0- Activity Does Not OccurActivity Does Not Occur – The patient does not perform the activity, and a helper does not perform the activity for the patient during the entire assessment time frame. Use of this code should be rare.


https://www.cms.gov/medicare/medicare-fee-for-service-payment/inpatientrehabfacpps/downloads/irfpai-manual-2012.pdf


Description

SKILLED NURSING FACILITY 

 

Skilled nursing facility (SNF) care consists of skilled nursing care and skilled therapy services provided on a continuous, daily basis, in an SNF. In order for a service to be considered skilled, the service, due to its inherent complexity, can be performed safely and/or effectively only by or under the supervision of skilled nursing or skilled therapy professionals. Examples of SNF care include physical therapy or intravenous therapy that can only be administered by an eligible professional provider (i.e., qualified nurse or therapist, or physician).


Custodial care is provided primarily to assist the patient in meeting activities of daily living. Such care is not provided primarily for its restorative or therapeutic value in the treatment of an illness, injury, disease, or condition. Custodial care includes, but is not limited to, help in walking, bathing, dressing, feeding, preparation of special diets and supervision of self-administration of medications that do not require the technical skills or professional training of medical or nursing personnel in order to be performed safely and effectively.


References

American Occupational Therapy Association (AOTA). Fact sheet. Occupational therapy's role in skilled nursing facilities. [AOTA Web site]. 2015. Available at: http://motfieldwork.pbworks.com/w/file/fetch/107071176/factsheet_skillednursingfacilities.pdf. Accessed May 15, 2025.


American Occupational Therapy Association (AOTA). Occupations. [AOTA Web site]. 2014. Available at: https://www.aota.org/advocacy/advocacy-news/coding/~/media/391EBF0C2F39446E908A525CA22272B0.ashx. Accessed May 15, 2025.


Centers for Medicare & Medicaid Services (CMS). Criteria for skilled services and the need for skilled service. 42 CFR Pt. 409.32. [U.S. Government Information Web site]. 10/01/2017. Available at: https://www.govinfo.gov/content/pkg/CFR-2017-title42-vol2/pdf/CFR-2017-title42-vol2-sec409-32.pdf. Accessed May 15, 2025.


Centers for Medicare & Medicaid Services (CMS). Examples of skilled nursing and rehabilitative services. 42 CFR Pt. 409.33. [U.S. Government Information Web site]. 10/01/2017. Available at: https://www.govinfo.gov/content/pkg/CFR-2017-title42-vol2/pdf/CFR-2017-title42-vol2-sec409-32.pdf. Accessed May 15, 2025.


Centers for Medicare & Medicaid Services (CMS). Medicare Benefit Policy Manual. Chapter 1 - Inpatient hospital services covered under part A. [CMS Web site]. 08/06/2021. Available at: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/bp102c01.pdf. Accessed May 15, 2025.


Centers for Medicare & Medicaid Services (CMS). Medicare Claims Processing Manual. Chapter 6: SNF inpatient part A billing and SNF consolidated billing. [CMS Web site]. 10/05/2023. Available at: https://www.cms.gov/regulations-and-guidance/guidance/manuals/downloads/clm104c06.pdf. Accessed May 15, 2025.

 
Centers for Medicare & Medicaid Services (CMS). Medicare Benefit Policy Manual. Chapter 8: Coverage of extended care (SNF) services under hospital insurance. [CMS Web site]. 10/05/2023. Available at: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c08pdf.pdf. Accessed May 15, 2025.


Centers for Medicare & Medicaid Services (CMS). Medicare Benefit Policy Manual. Chapter 16 - general exclusions from coverage. 110 - Custodial Care Transmittal for Chapter 16. [CMS Web site]. 01/05/2015. Available at: https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c16.pdf. Accessed May 15, 2025.

Centers for Medicare & Medicaid Services (CMS). Skilled nursing facility prospective payment system. [CMS Web site]. 10/01/2022. Available at: https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/SNFPPS. Accessed May 15, 2025.

Centers for Medicare & Medicaid Services (CMS). Skilled services requirements. 42 CFR Pt. 409.44. [U.S. Government Information Web site]. 10/01/2017. Available at: https://www.govinfo.gov/content/pkg/CFR-2016-title42-vol2/pdf/CFR-2016-title42-vol2-sec409-44.pdf. Accessed May 15, 2025.


Centers for Medicare & Medicaid Services (CMS). The inpatient rehabilitation facility–patient assessment instrument (irf-pai). Training manual. [CMS Website]. 10/01/2012. Available at: https://www.cms.gov/medicare/medicare-fee-for-service-payment/inpatientrehabfacpps/downloads/irfpai-manual-2012.pdf. Accessed May 15, 2025.


Centers for Medicare & Medicaid Services (CMS). The long-term care facility resident assessment instrument user's manual for version 3.0. Activities of daily living assistance. [CMS Web site]. 10/01/2019. Available at: https://downloads.cms.gov/files/mds-3.0-rai-manual-v1.17.1_october_2019.pdf. Accessed May 15, 2025.


Evidence of Coverage.


Kane RL. Finding the right level of posthospital care: "We didn't realize there was any other option for him." JAMA. 2011;305(3):284-293.

Medicare Payment Advisory Commission (MedPAC). Medicare coverage of and payment for home infusion therapy. Chapter 6. [MedPAC.gov Web site]. June 2012. Available at: https://www.medpac.gov/wp-content/uploads/import_data/scrape_files/docs/default-source/reports/chapter-6-medicare-coverage-of-and-payment-for-home-infusion-therapy-june-2012-report-.pdf. Accessed May 15, 2025.


National Pressure Ulcer Advisory Panel (NPAUP). Revised National Pressure Ulcer Advisory Panel Pressure Injury Staging System. 2016. Available at: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5098472/pdf/wocn-43-585.pdf. Accessed May 15, 2025.


Novitas Solutions, Inc. Bulletin. Skilled nursing facility level of care. [Novitas Solutions Web site]. 05/18/2017. Available at: https://www.novitas-solutions.com/webcenter/portal/MedicareJL/pagebyid?contentId=00147582. Accessed May 15, 2025.


U.S. Department of Health and Human Services. Subacute care: review of the literature. [HHS Web site]. December 1994. Available at: at: https://aspe.hhs.gov/system/files/pdf/138576/scltrves.pdf. Accessed May 15, 2025.​​


Coding

CPT Procedure Code Number(s)
N/A

ICD - 10 Procedure Code Number(s)
N/A

ICD - 10 Diagnosis Code Number(s)
Report the most appropriate diagnosis code in support of medically necessary criteria as listed in the policy.

HCPCS Level II Code Number(s)
N/A

Revenue Code Number(s)
The following coding information does not supersede the terms outlined in the Company SNF Contracts

0190 Subacute Care-General

0191 Subacute Care-Level I

0192 Subacute Care-Level II

0193 Subacute Care-Level III

0194 Subacute Care-Level IV

0199 Subacute Care-Other Subacute Care




Coding and Billing Requirements


Policy History

Revisions From MA02.004a:
​07/09/20245
​​This policy has been reissued in accordance with the Company's annual review process.​​
​01/06/2025

​​This version of the policy will become effective 01/06/2025. ​


The terms, Rehabilitation Services and Skilled Rehabilitation, have been revised throughout the policy to: Skilled Therapy Services and Skilled Therapy.

 

The medically necessary criteria have been revised to clarify and reflect recommendations from the Centers for Medicare & Medicaid Services (CMS).  The intent of the policy has not changed. 

 

The following criterion has been added to this policy:

  • CONTINUED STAY: SKILLED NURSING​​ FACILITY (SNF)

The following criteria have been revised:

  • NOT MEDICALLY NECESSARY
  • ​​CUSTODIAL CARE​​

Revisions From MA02.004:
01/01/2024
Effective 01/01/2024 this policy applies to New Jersey Medicare Advantage (MA)​ lines of business.
​06/14/2023

The policy has been reviewed and reissued to communicate the Company's continuing position on Skilled Nursing Facility (SNF): Skilled and Subacute Levels of Care​.​

10/19/2022

​The policy has been reviewed and reissued to communicate the Company's continuing position on Skilled Nursing Facility (SNF): Skilled and Subacute Levels of Care​.​

​​11/17/2021​
​This policy has been reissued in accordance with the Company's annual review process.​
11/01/2020

This version of the policy will become effective 11/01/2020.​ 

The following new policy has been developed to communicate medical necessity criteria for skilled and subacute levels of care in a Skilled Nursing Facility in accordance with Centers for Medicare and Medicaid Services (CMS).​ ​

______________________________________


Note: This version of the policy will become effective 11/01/2020.

The policy in Notification was updated 09/17/2020, 09/25/2020 with the following information:​

  • Clarify complex wound care with examples
  • Include occupational therapy as part pain management that requires medication management (with adjustments), and physical therapy
  • Revise maintenance therapy as medically necessary:

Maintenance therapy consists of activities that preserve the individual's level of function or prevent regression of that function. Maintenance begins when the therapeutic goals of a plan of care have been achieved or when no further progress is apparent or expected to occur. 

Maintenance therapy is considered medically necessary and therefore, covered when the specialized skill, knowledge and judgement of a qualified professional is required to establish, instruct and carry out a program to maintain the individual's current condition or to prevent or slow further deterioration.

Documentation with objective evidence or a clinically supportable rationale is needed to support the necessity of the skilled services provided and the individual's response to treatment.

  • Revise examples of Nursing Services to a Skilled Level of Care


1/6/2025
1/6/2025
7/9/2025
MA02.004
Medical Policy Bulletin
Medicare Advantage
No