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Update on COVID-19 Transfer Scenarios

On April 13, 2020, CMS provided additional information regarding transferring or discharging residents based on COVID-19 status. In summary, if two or more certified LTC facilities wish to transfer or discharge residents between themselves for the purpose of cohorting, no additional approval is needed. However, if a certified LTC wishes to transfer or discharge a resident to a non-certified facility, approval from the State Survey Agency is required.

A complete copy of the guidance provided can be found at

As always, the attorneys at Sandberg Phoenix are available to answer questions or assist with any needs you have.

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