Today's COVID-19 Report: Monday, April 27, 2020
Monday, April 27, 2020
Here are the latest need-to-know updates for Monday, April 27 regarding the COVID-19 pandemic.
Expanded Testing Opportunity, along with Caution
On Wednesday April 22, ODH recategorized asymptomatic nursing and assisted living residents with known COVID exposure into the same group as symptomatic residents which permits an expansion of critically important testing. While some facilities fear that this widespread testing may cause a spike in the published numbers of COVID positive and probable cases, this recategorization will permit a more strategic use of staff and judicious use of PPE. Dr. John Weigand, Central Ohio Geriatrics, stated:
“I am convinced of the absolute need for widespread testing in a focused manner of residents and staff to assist in the cohorting of patients and to ‘flatten the curve’ in congregate settings where COVID exposure exists. While facilities may struggle with this vital testing and confirming multiple residents’ COVID status because of the optics that they are a substandard facility, I contend the risk is even greater if they don’t do this testing. The PPE conundrum is made better with cohorting and staffing issues can be made better, as well.”
Note that this change in prioritization does not permit a facility to test all of its residents if there has been no known exposure. While some questions remain, it appears that the Families First Coronavirus Response Act ensures that Medicare, Medicaid and other health insurers reimburse providers for testing costs.
With more widespread testing within long-term care settings, the numbers of long-term care-associated cases are poised to grow. LeadingAge Ohio is encouraging ODH to expand the explanatory language published on its website with the nursing home listing, with a goal of educating families and the media on how easily COVID spread through nursing homes. While PPE supplies and testing access have improved in the past week to 10 days, these two limiting factors are driving increased numbers of individuals affected in congregate settings.
Similar data on COVID positive/probable patients may soon be released for the hospitals.
Finally, LeadingAge Ohio offers a word of caution due to rumors of widespread marketing of serology-based testing. The effectiveness of this type of testing is a matter of continuing debate and purchasing testing for all residents is discouraged, and also not likely covered by the reimbursement of the Families First Coronavirus Recovery Act. Members are encouraged to access only testing through ODH approved programs. Over the course of the next several weeks, as hospitals form clinical coalitions in their local networks as described on last Thursday's all-member call, further guidance may become available.
Star Ratings Freeze
On Friday, the Centers for Medicare & Medicaid Services (CMS) announced (QSO-20-28) a freeze to nursing homes' current overall star ratings on the Nursing Home Compare website following the suspension of certain survey inspections during the coronavirus pandemic. This is an update to its March 20 memo, in which CMS announced that it would suspend standard surveys for nursing homes and prioritize inspections regarding Immediate Jeopardy, infection control and self-assessments.
The the memo, CMS stated:
“There is a great shift in the number of nursing homes inspected, and how the inspections are conducted. This would disrupt the inspection domain of the Nursing Home Five Star Quality Rating System because many nursing homes that would normally be inspected, will not, thereby over-weighting and impacting the ratings of those facilities that are inspected. This could then potentially mislead consumers. Therefore, we will temporarily maintain and hold constant the health inspection domain of the rating system. Specifically, results of health inspections conducted on or after March 4, 2020, will be posted publicly, but will not be used to calculate a nursing home’s health inspection star ratings. This action will start with the scheduled update to the Nursing Home Compare website on April 29, 2020. The surveys will be posted through a link on the front page of the Nursing Home Compare website in the upcoming months (as the survey data is finalized and uploaded).”
MDS and PBJ Deadlines Waived
In the same memo from the Centers for Medicare & Medicaid Services, QSO-20-28, CMS announced that, to help facilities focus their efforts on protecting their residents from COVID-19, it is waiving the timeframe requirements for submitting resident assessment data (minimum data set (MDS)) and staffing data (Payroll-Based Journal (PBJ)) by certain deadlines. They note that the waivers related to the timing of MDS and PBJ data submissions will not impact the updates to the quality measures and staffing domains used for the April update of the rating system on April 29, 2020, because the underlying data for these domains is based on time periods that occurred prior to the COVID-19 crisis (e.g., prior to the Secretary declaring a Public Health Emergency on January 31, 2020). CMS is continuing to monitor the situation closely and will communicate any changes with the stakeholders as soon as possible.
CMS Nursing Home FAQs Underscore Policies Related to Admission of Hospice Staff
Since the onset of COVID-19, the growing concerns around the vulnerability of patients in nursing homes and other congregate living arrangements has led to severe access issues for hospice workers and other providers serving residents of long-term care facilities. In response to concerns surrounding the inability to fully address patient care needs due to various admission prohibitions, the Centers for Medicare & Medicaid Services (CMS) has issued several memoranda to nursing homes that outline expectations related to hospice worker access to facility patients. Coverage by the National Association for Home Care & Hospice (NAHC) of previous notices that address access to facility patients is available HERE.
Late Friday, as part of a memorandum to state survey agency directors (QSO-20-28-NH): Quality Nursing Home Five Star Quality Rating System updates, Nursing Home Staff Counts, and Frequently Asked Questions), CMS provided a recap of previous guidance related to access to facility patients by health care workers -- including hospice workers. An excerpt of the Q&A is below.
Q: What type of health care workers are allowed to enter a nursing home?
A: The CMS memorandum (QSO-20-14-NH (Revised)) states that health care workers who do not work in a nursing home, such as hospice workers, surveyors, Emergency Medical Services (EMS) personnel, or dialysis technicians, should be permitted to come into the facility as long as they meet the CDC guidelines for health care workers. Facilities should screen health care workers based on this CDC guidance with exceptions made for urgent entry to deliver emergency care (e.g., EMS) so they can attend to the emergency without delay. We note that the memorandum does not (and cannot) describe every type of service, person, or scenario that may exist in facilities. There are likely other types of health care workers that can be permitted to enter the facility (e.g., lab technicians, radiology technicians, home health nurses, etc.). However, CMS cannot and should not dictate every situation in which a provider could enter a nursing home, because, again, such decisions should be made by nursing homes in consultation with patients, residents, family members, and the other health care providers.
To determine if a health care worker should enter the facility, facilities should evaluate their residents’ needs, the services needed to meet those needs, and the individuals who provide those services. Facilities should also ensure that the precautions needed to prevent COVID- 19 transmission will be available for any individual that enters the facility (e.g., PPE availability). In other words, there is not a blanket approval for all health care workers to always be allowed to enter. Similarly, CMS has not enacted a blanket ban on any type of health care worker. On a case-by-case basis, facilities should permit a health care worker to enter by determining if the services they provide are essential to continue, need to be discontinued or postponed, or can be done remotely. Note, due to the risk COVID-19 poses to nursing home residents, we recommend facilities only continue critical services, and only allow individuals who are essential to provide those critical services into the facility.
CMS also encourages the use of telehealth, so residents can be seen virtually by their practitioner. CMS recently released a nursing home telehealth toolkit that facilities may find helpful.
CMP Dollars Available to Support IT, Remote Support
On Friday, April 24, the Ohio Department of Medicaid alerted Ohio nursing homes to the availability of Civil Monetary Penalties (CMP) funds to support purchases of electronic devices which facilitate communication and socialization for nursing home residents, including tablets, ipads, and similar devices, as well as accessories such as adaptive accessories, covers to facilitate cleaning between uses, and other items.
The grants of up to $3,000/provider may be made to providers that complete an application template provided by ODM; applications should be sent to Amy Hogan, Nursing Facility Policy Administrator at firstname.lastname@example.org. ODM also shared an FAQ document, as well as a sample approval letter for the grants.
CMP grants have typically been made available to innovative projects that improve the quality of life of nursing home residents. LeadingAge Ohio encourages members to take this opportunity to support communication during a period when many nursing home residents are isolated from their family and loved ones.
HHS Releases New Information on Attestation and Terms & Conditions for Provider Relief Funds
Late Sunday, HHS updated the CARES Act Provider Relief Fund website to include additional information on the steps Medicare providers must take to receive and/or retain the Provider Relief Funds. The following is new:
- HHS clarified in an email that Medicare providers must attest to separate Terms & Conditions for each payment they receive from the Fund. The Terms & Conditions are slightly different between the first and second round of funds. These differences are detailed in the updated version of the LeadingAge Provider Relief Fund Background document.
- Medicare providers who received the second round of funds will use the newly-created General Distribution Portal to upload the required financial information. Through this portal, providers will need to attest to each payment associated with their billing Taxpayer Identification Number(s) and upload their most recent IRS tax filings as well as estimates of lost revenues, but the Application Guide provided by HHS assists providers with uploading the financial data to the portal.
- Providers still have 30 days to go to the CARES Provider Relief Fund website to attest to the two sets of Terms and Conditions.
HUD Resource Clarifies Tenant Rent Responsibilities
HUD’s Office of Multifamily Housing (MFH) produced a rent brochure that discusses steps residents can take in case of lost income during the COVID-19 national emergency and explains the eviction moratorium in the CARES Act. In communication to stakeholders, HUD encouraged owners to share the resource widely and suggested emailing it to residents and posting in lobby, laundry, or meeting areas. Here’s an article about the rent update. Wednesday’s Housing Happenings call at 9 a.m. will cover this topic in more detail.
SNF Regional Meetings Rescheduled: Register Today
Join Stephanie DeWees, LeadingAge Ohio’s Quality & Regulatory Specialist for Long-term Care, as she provides updated information on a range of topics: infection control-focused surveys being conducted by CMS and ODH, implementation of the pre-surge planning tool kit, review of PPE guidance, and strategies to optimize PPE and more.
Ohio Statistics: 15,963 Cases, 728 Deaths
As of yesterday, there were 15,963 confirmed and probable cases of COVID-19 in Ohio and 728 confirmed and probable COVID-19 deaths. A total of 3,178 people have been hospitalized, including 952 admissions to intensive care units.
In-depth data can be accessed by visiting coronavirus.ohio.gov.
Please send all questions to COVID19@leadingageohio.org. Additionally, members are encouraged to visit the LeadingAge Ohio COVID-19 Working Group facebook group to pose questions to peers and share best practices.