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Update on Flexibilities Issued to Nursing Facilities During the COVID-19 Public Health Emergency


During the initial response to the coronavirus disease 2019 (COVID-19) pandemic, the South Carolina Department of Health and Human Services (SCDHHS) announced dozens of temporary policy changes designed to ensure ongoing access to care for Healthy Connections Medicaid members and children enrolled in the Individuals with Education Part C program, which is commonly known as BabyNet. Most of these policy changes were issued using emergency authorities derived from the federal public health emergency (PHE) and were issued for the duration of the federal PHE.

After evaluating utilization data and consulting with the state’s managed care organizations (MCOs), the provider community and other stakeholders, SCDHHS is announcing updates to the temporary nursing facility policy changes it previously issued. The updates announced in this bulletin are specific to the temporary policy changes created during the COVID-19 PHE and do not impact other agency policies that existed prior to the PHE, unless specifically indicated as such. The changes announced today will take effect once the current federal PHE has expired.

While the exact end date is not yet known, providers are advised that the Secretary of the U.S. Department of Health and Human Services previously announced that the federal PHE will remain in effect until at least April 11, 2023.

Medical University of South Carolina’s (MUSC) Medical University Hospital Authority (MUHA) Employee Testing Partnership

Upon expiration of the federal PHE, the COVID-19 testing resources provided through the partnership with MUSC’s MUHA, first announced in a provider alert issued Dec. 31, 2020, will no longer be available.  These tests were available to nursing facilities for full-time equivalent healthcare personnel within Healthy Connections Medicaid-enrolled nursing facilities. Healthy Connections Medicaid-enrolled providers will no longer be required to participate in this program as a condition of reimbursement.

Level of Care (LOC)/Notice of Admission

Upon the expiration of the PHE, the Centers for Medicare and Medicaid Services (CMS) will reinstate the requirement for a three-day prior hospitalization for coverage of a skilled nursing facility (SNF) stay. This requirement was waived during the federal PHE as described in a provider alert issued Aug. 27, 2020. This allowed temporary emergency coverage of SNF services without a qualifying hospital stay for those people who experienced dislocations or were otherwise affected by COVID-19.

SCDHHS will apply the standard LOC policy for all members, including those who are under observation, quarantined or have a diagnosis of COVID-19. Providers should resume following procedures for SCDHHS Form 181 as outlined in the instructions accompanying the form. The LOC requirements are described in Section 2 of the Nursing Facility Services Provider Manual.

Providers should direct any questions related to this bulletin to the Provider Service Center at (888) 289-0709. The Provider Service Center’s hours of operation are 7:30 a.m. – 5 p.m. Monday – Thursday and 8:30 a.m. – 5 p.m. Friday.

Thank you for your continued support of the South Carolina Healthy Connections Medicaid program.

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