DHS COVID-19 PROVIDER GUIDANCE // OLTL
Clarification Guidance for Pennsylvania
Pre-Admission Screening Resident
Issued: April 14, 2020
The CMS Center for Clinical Standards and Quality (CCSQ) has issued a
communication to nursing facilities and hospitals entitled "COVID-19 Emergency
Declaration Blanket Waivers for Health Care Providers," which includes a waiver for 42
C.F.R. § 483.20(k) for PASRR activities.
Pennsylvania has consulted with the PASRR Assistance Technical Center (PTAC) for
clarification on this guidance. PTAC has advised that the emergency blanket 1135
waiver of 42 C.F.R. § 483.20(k), means that nursing facilities will not be cited by
surveyors for non-compliance with federal PASRR requirements if they admit people
with incomplete PASRR documentation during the crisis. It does not, however, waive
PASRR requirements in 42 C.F.R. § 483.100-138. PTAC advises that states must
continue to comply with these requirements, unless they wish to provide additional
flexibility. In this case, states must submit a specific 1135 request for CMS’ approval.
Pennsylvania has requested and received approval from CMS for a 1135 waiver that
would allow suspension of the PASRR assessment process for 30 days. However,
Pennsylvania has decided to continue performing all PASRR activities through remote
means to ensure the fewest possible inappropriate nursing facility placements. For the
following reasons, Pennsylvania will only apply this 30-day waiver on a case-by-case
- Approximately one in four individuals who receive a PASRR Level II assessment
are determined to be inappropriate for nursing facility placement, because they
are in need of a different kind of care. A blanket waiver allowing for the 30-day
time frame would create disruptions for those individuals whose care
requirements are determined to be inappropriate for nursing facility placement
after they were already placed.
- Nursing facilities are experiencing capacity pressure and other challenges due to
the COVID-19 outbreak and a blanket waiver would only increase this pressure.
- A blanket waiver is only approved for 30 days, and assessors may potentially
have to address a backlog when the COVID-19 crisis period is still active.
- The PASRR process in most cases is still being completed in the hospital without
disruption. The case-by-case approach will focus this flexibility only where
Nursing Facilities will continue to require the Level I for everyone admitted to their
nursing facility. Aging Well will continue to review individuals in hospitals prior to
admission to the nursing facility for clinical eligibility and to do the PASRR Level II if it is
required. The only exception to this process should be for individuals that meet
Exceptional Admission criteria for admission to the nursing facility without needing to
have the full Level II process done. If a hospital is full, and in need of beds specifically to serve patients with COVID-19, please contact Ruth Anne Barnard, firstname.lastname@example.org, to
request additional exceptions.
Questions regarding current PASRR requirements can be emailed to Ruth Anne
Barnard, PASRR Coordinator, Office of Long-Term Living, at email@example.com.