SPECIAL BULLETIN COVID-19 #45: Increase in Therapeutic Leave Days for ICF/IDD Facilities Due to COVID-19
Author: NCTracks: (800) 688-6696; NCTracksProvider@nctracks.com
Background and General Guidance
Effective March 10, 2020, through the conclusion of the North Carolina declared state of emergency related to the COVID-19 crisis, NC Medicaid is temporarily increasing the number of therapeutic leave days for Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF-IIDs) from 60 days to 90 days and waiving the requirement of approval needed more than 15 consecutive days per Clinical Coverage Policy 8E. At the time of the initiation of the extended leave request the provider should document the leave in the record and confirm with the beneficiary/guardian the intent to return to the facility and any specific instructions related to meeting the IDD and physical health care needs of the beneficiary. The provider should check in with the beneficiary/guardian at least every 15 days and document this check in the record in to ensure the beneficiary’s needs are still being met and that there is still an intent to return the facility.
If the attending physician determines that a therapeutic leave could potentially place a beneficiary at greater risk of COVID-19 compared to staying in the ICF or that they therapeutic leave is medically/clinically inappropriate, then the beneficiary/guardian will be informed that therapeutic leave is not recommended. If the beneficiary/guardian removes the beneficiary against the advice of the attending physician, the provider may then choose to discharge the beneficiary with contractually agreed upon notice.
ICF-IIDs shall reserve a therapeutically absent beneficiary’s bed and are prohibited from deriving any Medicaid revenue for that beneficiary other than the reimbursement for the bed during the period of absence. ICF-IIDs are reimbursed at their full current Medicaid bed rate for a bed reserved due to therapeutic leave. ICF-IIDs use RC183 to bill therapeutic leave days. In the event that the beneficiary is hospitalized during the therapeutic leave, the ICF-IDD may continue to bill therapeutic leave. During the time of therapeutic leave, the ICF-IDD is still responsible for coordinating care for the beneficiary.
This extension of Therapeutic Leave also applies to any LME/MCO Medicaid-approved services that are “in lieu of” ICF-IID where therapeutic leave is part of the existing in lieu of service definition.
Please note that providers may request that beneficiaries who choose extended therapeutic leave remain with their family to reduce potential exposure and adhere to Governor’s EOs around social distancing. Providers who choose to allow beneficiaries to return to their facility prior to the end of this crisis may implement screening procedures recommended by the CDC to determine if the beneficiary may return to the facility.
Temporary Modifications to Therapeutic Leave: Claims-Related Information
Retroactive to March 10, 2020, through the conclusion of the state of emergency related to COVID-19, NC Medicaid is temporarily modifying Clinical Coverage Policy 8E. Intermediate Care Facility for Individuals with Intellectual Disabilities (ICF-IID). Provider(s) shall comply with the “NCTracks Provider Claims and Billing Assistance Guide,” Medicaid Bulletins, fee schedules, NC Medicaid’s clinical coverage policies and any other relevant documents for specific coverage and reimbursement for Medicaid and NC Health Choice.
NC Medicaid COVID-19 Resources website: http://www.medicaid.ncdhhs.gov/coronavirus
Screening Procedures Recommended by CDC: https://www.cdc.gov/coronavirus/2019-ncov/hcp/guidance-risk-assesment-hcp.html