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November 19, 2020

Franklin Becomes Ohio's First Purple County. In today's Ohio Public Health Advisory System (OPHAS) posting, Franklin County appeared as purple, a first for the state. Franklin County consistently leads the state in COVID-19 statistics. Purple status does not result in any mandatory action, but is defined as "[s]evere exposure and spread. Only leave home for supplies and services. Follow all current health orders." With the exception of 12 eastern and southeastern counties and three in the northwest part of the state, the rest of Ohio is red. In his press conference today, Governor Mike DeWine announce the new OPHAS map and updated the serious situation with Ohio's hospitals:

As of today, there are 3,829 hospitalized COVID-19 patients in Ohio, with 943 of those individuals in the ICU. These are the highest patient counts Ohio has had during the pandemic and more than double the hospitalizations recorded during previous peaks.

While statewide testing has increased by 43 percent, positive cases have increased by nearly 300 percent in the past month. 

New health data compiled by the Ohio Department of Health revealed today that Franklin County has reached a Level 4 Purple Public Emergency with severe exposure and spread. All 88 counties remain at "high incidence" as defined by the Centers for Disease Control and Prevention. For the first time, no counties are rated below Level 2. 

"Other counties may not yet be seeing continuous, uninterrupted increases in the same way as Franklin County, but make no mistake - almost all counties are seeing more cases and more healthcare use that could threaten the medical system if they continue," said Governor DeWine.

Clarification on POC Test Result Reporting. We stated on several occasions, such as yesterday's assisted living member call, that both aggregate point-of care (POC) testing data and line-level data must be reported on a daily basis by any location that performs these tests under a Clinical Laboratory Improvement Amendments (CLIA) Certificate of Waiver. This is not correct. Only the aggregate data need to be reported daily. The line-level data must be reported within 24 hours after a test is performed. The Department of Health and Human Services (HHS) directive on this topic is slightly ambiguous ("report data for all testing completed, for each individual tested,within 24 hours of results beingknown or determined, on a daily basis") but the Department of Health language is clearer ("electronically report within twenty-four (24) hours the results of all such examination, including, but not limited to: positive, negative, invalid, and inconclusive results").

Another POC test reporting question is whether a SNF that tests assisted living staff in addition to its own staff must report the results to the National Healthcare Safety Network. The answer is yes, all POC tests performed by a SNF must be reported. The requirement is location-specific (the "laboratory"), not person-specific.

Another Testing Question: Red County. The following is a member question we received today. We thought the answer would be relevant to many members because of the proliferation of Centers for Medicare and Medicaid Services (CMS) red counties.

Many of our facilities are in CMS red counties and must test staff twice weekly. Because of the holidays, their Friday state-supported testing was moved to Wednesday. There is supposed to be a 3-day gap between the twice-a-week testing, which would require them to test on weekends. It also would require most of our staff to show up at the facility 6 days a week. Is there any exception to the 3-day rule that would allow them to test sooner? They deserve the time away from the facility, plus getting staff to come in on a weekend to test on their day off is asking a lot.

The answer is that a three-day gap between tests is not required. Staff only must be tested twice a week. It also is not necessary to test all staff on the same days. For state-supported polymerase chain reaction (PCR) testing, the pick-up date is locked in, but we recommend using reasonable discretion on collecting the specimens to correspond with when staff work as much as possible. For other tests (BinaxNOW, facility-arranged laboratory) there is even more flexibility.

More Thoughts on CMS Holiday Guidance. A controversial aspect of the CMS holiday alert issued yesterday for SNF patients is that it does not require quarantining patients who disregard CMS's advice and leave the facility for a holiday visit with family or friends. Instead, CMS writes:

Place the resident on transmission-based precautions (TBP) if the resident or family member reports possible exposure to COVID-19 while outside of the nursing home, or if the resident has signs or symptoms of COVID-19 upon return. Please note that residents and loved ones should report to the nursing home staff if they have had any exposure to COVID-19 while outside of the nursing home.

Consider placing residents on TBP if they were away from the nursing homes for more than 24 hours.

As we wrote in last night's COVID-19 Update, this language does not prohibit a SNF from adopting a policy to quarantine anyone who goes out for a holiday visit in the community, especially if the center is in a red county or the resident visits a location in a red county. We believe the most prudent course for SNFs located in red counties, or even orange counties, is to quarantine anyone who goes out for such a visit. Ohio defines these counties as "very high exposure and spread" and "increased exposure and spread," respectively, making it quite possible that a person who gathers with others outside the facility will be exposed. While a surveyor could fault a SNF for quarantining a person who does not end up contracting COVID-19, we view the risk of not quarantining someone who turns out to be infected as significantly greater. Given asymptomatic/pre-symptomatic spread of COVID-19, we believe it is not a risk worth taking.

Will Your SNFs Qualify for the October QIP Payment? AHCA deciphered much of the mystery around why some SNFs qualified for the September HHS Quality Incentive Program (QIP) payment and others did not. Now AHCA has evaluated whether centers will receive the October installment. The following is a message from AHCA on this topic.

We are unsure if HHS has conducted the calculations for October - there may be time to go back and correct October data. This excel file only contains SNFs that data indicates they may be excluded from receiving any payment in October.

Use this file to search for your facility's weekly NHSN submissions. You can filter (in the top row) by facility name or FPN - the past 14 weeks of submissions for your facility is shown.

If column H in the attached file ("Will the Facility be excluded for not submitting data to NHSN?") is 'Yes', then look for 'N' in column F of your NHSN submissions (link above). Please enter in data by following the steps outlined here for the specific week(s) your facility is missing data.

If column I, J or K in the attached file is 'Yes', then look for 'N' in column G of your NHSN submissions (link above). We strongly encourage you to review our document on resolving Quality Assurance (QA) issues to help identify any issues with the specific week and update any data by following the steps outlined here. If your data is correct after reviewing, please email to remove the Quality Assurance issues from your data.

Although your facility may not qualify for payment due to high facility COVID infection rates, it is still a good idea to address any issues outlined here, as facilities can qualify for future months' payments.

Please direct any non-QA related questions to

Molina to Waive MyCare Medicare SNF Prior Authorizations. On a call today with OHCA, Molina Healthcare confirmed that they will waive prior authorization for SNF admissions under their MyCare Ohio Medicare product line. Last week's Department of Medicaid directive suspended prior authorization requirements for Molina Medicaid and MyCare Medicaid admissions to SNFs, effective November 12, 2020. A notice to providers about the Molina MyCare Medicare admissions is forthcoming.