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November 18, 2020


CMS Holiday Alert to SNF Residents, Families, and Staff. This evening, the Centers for Medicare and Medicaid Services (CMS) issued an alert for SNFs urging holiday precautions. While specifically addressing SNF residents, the non-mandatory guidance is appropriate for residents of any congregate setting serving vulnerable people. Importantly, CMS wrote:

We also know that some residents may want to leave the nursing home temporarily to visit family and friends for the holidays or other outings. While CMS supportfamily engagement and a resident’s right to leave the nursing homeeveryone needto work together to take extra precautions to help reduce the spread of COVID-19, which can pose an elevated danger to the health of nursing home residentsTherefore, CMS recommends against residents leaving the nursing home during this PHE.

The guidance notes circumstances that would increase risk if a resident leaves the facility and advises providers to educate residents and families about the risks and to offer alternative means of contact. CMS also gives a lengthy list of precautions that families should take if a resident does go out.

In a brief comment, CMS recommends that facility staff take the same precautions for the holidays.

When a resident who has gone out returns, CMS suggests screening, testing, and quarantine. The quarantine suggestion, though, is limited to cases when the resident has possible exposure to COVID-19, exhibits symptoms, or was out for more than 24 hours. In our reading of the CMS guidance, it does not prohibit a facility from quarantining all residents who go out for a holiday as an extra precautionary measure, but it is not recommended.

Long-Term Care Cases Up Again. This week, data posted by the Department of Health (ODH) showed an increase of 908 COVID-19 cases (22%) in the state's SNFs, assisted living communities, and ICFs/IID compared to last week. As a point of reference, this weekly increase is about the same as the total number of cases the week of June 24. Since the state began to publish statistics on April 15, there have been more than 21,000 cases among facility residents and more than 14,000 among staff. Total mortality reached 3,154. 

Pfizer Moves Closer to Vaccine EUA. Pfizer and its COVID-19 vaccine development partner, BioNTech, provided updated information about their clinical trials today. They finished their Phase 3 analysis and plan to submit to the Food and Drug Administration for an Emergency Use Authorization (EUA) shortly. Here are bullet points from the press release summarizing the developments, which highlight effectiveness for people over 65:

  • Primary efficacy analysis demonstrates BNT162b2 [the vaccine] to be 95% effective against COVID-19 beginning 28 days after the first dose;170 confirmed cases of COVID-19 were evaluated, with 162 observed in the placebo group versus 8 in the vaccine group
  • Efficacy was consistent across age, gender, race and ethnicity demographics; observed efficacy in adults over 65 years of age was over 94%
  • Safety data milestone required by U.S. Food and Drug Administration (FDA) for Emergency Use Authorization (EUA) has been achieved
  • Data demonstrate vaccine was well tolerated across all populations with over 43,000 participants enrolled; no serious safety concerns observed; the only Grade 3 adverse event greater than 2% in frequency was fatigue at 3.8% and headache at 2.0%
  • Companies plan to submit within days to the FDA for EUA and share data with other regulatory agencies around the globe
  • The companies expect to produce globally up to 50 million vaccine doses in 2020 and up to 1.3 billion doses by the end of 2021
  • Pfizer is confident in its vast experience, expertise and existing cold-chain infrastructure to distribute the vaccine around the world

UHC Waives Prior Authorization for Multiple Product Lines. Effective November 16, 2020, through December 16, 2020, UnitedHealthcare (UHC) waived prior authorization request for admission to SNFs for Medicare Advantage and Group Market health plan members. OHCA confirmed that the waiver also applies to UHC Connected MyCare Medicare beneficiaries. Last week's Department of Medicaid (ODM) directive suspended prior authorization requirements for UHC Community Plan Medicaid and MyCare Medicaid admissions to SNFs effective November 12, 2020. Please note UHC indicates they may conduct selective retrospective reviews for services rendered during this time. Additionally, admission notification is still required. If you have questions, please contact Gary Grosel, M.D., UnitedHealthcare Market Chief Medical Officer, at gary_grosel@uhc.com or 216-263-9533.

Medigold Waives SNF Prior Authorizations. Today, Medigold sent the following notice to providers:

We are waving the authorization requirement for skilled nursing admissions for 30 days, immediately and through December 12, 2020.

• Please notify the plan of admission the same day the member arrives at your facility.

• An update will be required within 2 days of admission to your facility.

• Our team will continue to follow their stay and provide next review dates with each update.

• Fax is the preferred avenue for admission notifications and concurrent review

• Watch your emails for updates.

For questions, please contact the provider contact center at 1-900-991-9907

Update of ID/DD Providers. Many ICFs/IID have begun to receive BinaxNOW test kits from their county boards. As we shared previously, ICFs need to have a Clinical Laboratory Improvement Amendments (CLIA) Certificate of Waiver to utilize these tests. OHCA confirmed with ODH that ICF providers who wish to administer BinaxNOW tests at a home office that is not part of their ICF can apply for the Certificate of Waiver and select ICF as the provider type, with the address of their home office. As a reminder, a separate Certificate of Waiver is needed for each address where testing is administered.

In addition, COVID-19 cases and deaths in the DD system both increased by around 10% in just the last week, leading many residential providers to question whether residents' planned visits home for Thanksgiving should proceed. While there may be situations where it is determined that residents should not leave the home, those decisions still need to be made through individualized conversations based on each situation. The increase in cases in each community and any public health advisories should be taken into consideration, but the Department of Developmental Disabilities (DODD) does not support agency-wide policies prohibiting visits with friends and families. Please also see this message from DODD Director Jeff Davis and Medical Director Dr. Laura Sorg to the DD field related to the recent increase in COVID-19 cases.

HHS Updates Provider Relief Fund FAQs on Capital Costs. The Department of Health and Human Services (HHS) added two new items to its frequently-asked questions (FAQs) on the Provider Relief Fund today. These two items (see pages 15-16) address capital expenditures, both for equipment and for facilities. In a change from previous guidance, HHS wrote that these expeditures "may be fully expensed only in cases where the purchase was directly related to prevent, prepare for and respond to the coronavirus." The FAQs give examples of each type of item that would be considered related to coronavirus.

Left-Over Chat Questions from Yesterday's SNF Member Call. Here are a few questions that we were unable to take on the SNF call, with answers.

Q. If we are in outbreak testing, now that the county is red with CMS, do the residents have to be tested twice/week as well as all staff twice/week?

A. No, when a SNF is in outbreak mode, residents must be tested every 3-7 days after the initial test. This is the same regardless of the county color code. So in a CMS red county, staff would be tested twice a week and residents at least once a week.

Q. How are compassionate care visits/end of life visits being handled in CMS red counties? Are those prohibited as well?

A. No, compassionate care visits are mandatory in all counties. The CMS color code does not affect this either.

Q. Can you go over the QSO requirement for checking county every two weeks?

A. Quality, Safety, and Oversight letter (QSO) 20-38-NH reads on this point, "[f]acilities should monitor their county positivity rate every other week (e.g., first and third Monday of every month) and adjust the frequency of performing staff testing according to the table above." After the QSO was published, CMS began to release new positivity data weekly, so we recommend establishing a day each week when you check the CMS county color and applying it on a go-forward basis. 

Q. Besides NHSN who else do we report covid deaths to?

A. The only required reporting for deaths is to the National Healthcare Safety Network (NHSN). County-level deaths among long-term care facility residents are reported on Ohio's COVID-19 dashboard, but facilities are not required to report.

Q. Where do I get the CSV file?

A. Assuming you mean the file for reporting point-of-care (POC) test results to ODH, you can find information about it on this web page under "Technical Specifications." Remember that SNFs are required to report line-level data to NHSN, not ODH, so the comma-separated values (CSV) file is only relevant for assisted living or other locations performing POC tests.

Online AL Test Reporting Closes at Midnight. The latest round of mandatory COVID-19 test result reporting for residential care facilities ends tonight at midnight. This round captures results of testing between October 26 and November 8, 2020. Please use the online tool if you have not yet reported for this period.

Exception Review Tip. In a meeting today on exception reviews with staff from ODM, they asked the provider associations to communicate to members that if a SNF is notified of an exception review, but is experiencing particular challenges because of COVID-19 (for example, an outbreak or a staffing shortage), the center can request postponement of the review. The ODM personnel stated that they check the ODH dashboard for outbreak status before even sending an exception review notice. They made these points to show that they consider the impact on patient care, in response to the associations' request for a general pause on exception reviews.