According to the RAI Manual, chapter 6:
“The interruption window is a 3-day period, starting with the calendar day of Part A discharge and including the two immediately following calendar days, ending at midnight. In other words, the resident must return to the same SNF by 11:59 p.m. at the end of the third calendar day. The interruption window begins on the first non-covered day following a Part A-covered stay and ends at 11:59 p.m. on the third consecutive non-covered day following a Part A-covered stay.”
If, for example, the resident left the facility on June 4th and returned on June 7th. This scenario is not an interrupted stay. The facility would need to complete a new 5-day assessment. The resident was gone for “3-midnights” on the 4th, 5th, 6th.
However, If the resident left on June 4th and returned on June 6th, this scenario Is an interrupted stay. The facility would not do another 5-day assessment.
Remember, the Interrupted stay policy applies anytime the Medicare part A stay ends, and the resident returns to skilled status in the same facility before the 3rd midnight. Residents that drop to a non-skilled level of care and stay in the facility are included in the Interrupted Stay Policy. The policy would also include discharged home residents or even leave Against Medical Advice (AMA).
When a resident returns from an interrupted stay, the facility should “just pick up where you left off.” Take the example above, the resident left on June 4th and returned on June 6th. Let’s assume that June 4th would have been the resident’s 22nd day of their stay. When the resident returns, the 6th now becomes the 22nd day of the stay. The facility does not need to complete a new 5-day assessment.
Summary
The Variable Per Diem Adjustment would remain as indicated for day 22 of the stay. The Physicians Certification will also be continued. In other words, the Medicare part A stay did not end; it was just “interrupted” for a couple of days.
Ensure that the interdisciplinary team knows when and how to utilize the Interrupted Stay Policy. If this policy is not applied appropriately, it may lead to an overpayment due to the variable per diem adjustments under PDPM.
Interrupted stays are a topic that is sure to be targeted by Medicare Administrative Contractors when auditing. The facility will want to correctly assign an interrupted stay according to policy to avoid additional audits and to the appearance of fraud or abuse.