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October 12, 2020


Project ECHO FAQ. Project ECHO (officially called AHRQ ECHO National Nursing Home COVID-19 Action Network - AHRQ is the federal Agency for Healthcare Research and Quality) issued a frequently-asked questions document that explains the initiative, which currently is recruiting both participating SNFs and training entities, called Hubs. Although the program is free and voluntary, SNFs are not automatically placed in the program but must sign up. There apparently are three Hubs so far for Ohio: MetroHealth, Ohio Health, and University of Cincinnati. To our knowledge, none of them have finalized contracts to serve in this capacity, but are expected to do so. OHCA is in touch with these potential Hubs to find out how we can help with the program.

SNFs can enroll to participate here. Completion of the 16-week program, which does not have a defined begin date yet, entitles the SNF to a $6,000 stipend. According to AHCA's Dr. David Gifford, Project ECHO is loosening the requirements to qualify for the stipend, but the materials do not disclose the changes or exactly what a facility must do to qualify. Project ECHO will hold three more introductory webinars (not part of the 16-week program) this week. Please see this flyer for details and registration.

PPE for Outbreaks in SNFs. Because of the strict definition of an outbreak under Centers for Medicare and Medicaid Services (CMS) and Centers for Disease Control and Prevention (CDC) guidelines (a single positive case among staff, contractors, consultants, volunteers, or patients), many centers are in outbreak status at any given time. By now, the testing regimen under CMS Quality, Safety, and Oversight letter 20-38-NH is well-known, but members ask about the personal protective equipment (PPE) requirements when a center is in outbreak mode, most notably in last week's SNF member Zoom meeting. It is not an extensive discussion, but this topic is addressed in CDC's "Responding to Coronavirus (COVID-19) in Nursing Homes." In the section on outbreaks (newly-identified, SARS-CoV-2-infected health care personnel (HCP) or residents), CDC writes:

HCP should use all recommended COVID-19 PPE for the care of all residents on affected units (or facility-wide if cases are widespread); this includes both symptomatic and asymptomatic residents.
  • If HCP PPE supply is limited, implement strategies to optimize PPE supply, which might include extended use of respirators, facemasks, and eye protection and limiting gown use to high-contact care activities and those where splashes and sprays are anticipated. Broader testing could be utilized to prioritize PPE supplies (see section on using testing).

The link CDC calls "all recommended COVID-19 PPE" actually is to a more extensive guideline that deals with various infection control topics, but there is a section in that guidance on "PPE recommended when caring for a patient with suspected or confirmed COVID-19," which appears to be CDC's intended reference. The recommended COVID-19 PPE is an N95 respirator, eye protection, gloves, and gown.

Conflicting CMS and HHS Guidance on Medicare Advance and Accelerated Payment Repayment. The following material is from an email by AHCA's Mike Cheek alerting members of conflicting language in guidelines from two different parts of the same federal agency. 

Unfortunately, [the Department of Health and Human Services (HHS)] and CMS have released conflicting guidance regarding whether Provider Relief Funds (PRF) may be used to repay Medicare Advance and Accelerated Payments (AAP) - see below:

  • CMS Medicare Learning Network Issuance:  States PRF may be used to repay Medicare Advance and Accelerated Payments; and

CMS Statement: “To allow even more flexibility in paying back the loans, the $175 billion issued in Provider Relief funds can be used towards repayment of these Medicare loans.”

  • HHS PRF Frequently Asked Questions Update (dated 10/9/20): States PRF may NOT be used to repay Medicare Advance and Accelerated Payments.

HHS FAQ (10/9/20):  Can providers use Provider Relief Fund distributions to repay payments made under the CMS Accelerated and Advance Payment (AAP) Program? (Added 10/9/2020) No, this is not a permissible use of Provider Relief Fund payments.

We have elevated the conflicting language both with CMS and the HHS PRF teams. As soon as we additional information we will alert you.  While this does not constitute legal or formal guidance, AHCA/NCAL is encouraging members to follow HHS guidance until clarification has been received from the Department.

Interestingly, the brief question and answer quoted above was the singular change HHS made to its FAQ on October 9, making it seem quite intentional and lending further credence to AHCA's advice.

Webinar on Coronavirus Relief Fund for Adult Day Care. The state allocated $15.2 million for Coronavirus Relief Fund (CRF) grants to adult day care centers and senior centers (see this memo for more information). Like previous CRF distributions, the purpose of the funding is to assist centers with costs, such as for testing and PPE, resulting from COVID-19. The state will hold a webinar on this opportunity Friday, October 16, from 10:00-11:30 a.m. Please use this link to register.