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October 19, 2020


Yet Another SNF Testing Plan Coming. Today Director of Aging Ursel McElroy explained, in a meeting with the SNF associations and the DeWine Administration "testing team," that a new state testing plan for SNFs is coming soon. It will involve mandatory weekly staff testing in all SNFs regardless of county color under either the federal or state system, except that the Centers for Medicare and Medicaid Services (CMS) mandates twice-weekly testing in CMS red counties (currently Athens, Butler, Richland, and Scioto). This means monthly testing in CMS green counties will be a thing of the past.

The DeWine Administration also will expand state support for testing to include all required tests, at the center's option. State support can be alternating polymerase chain reaction (PCR) and BinaxNOW tests every week, PCR tests every other week, or BinaxNOW tests every other week. Under the second and third options, the facility would be on its own for the alternate week. For the CMS red counties, the extra test each week would be filled in with BinaxNOW. A SNF still can opt out of state support completely if it chooses. The state also plans to send each SNF a 4-week supply of tests (half BinaxNOW and half PCR) that will be a reserve to use for the initial round of outbreak testing, as needed, or for the routine tests.

The new program will be announced tomorrow morning via the Enhanced Information Dissemination and Collection System (EIDC), including a new opt-in/opt-out tool and an explanatory webinar. A facility will be able to opt in or opt out only once a month. The state intends to start the new cadence next week and to send out the reserve supplies this week. Director McElroy also said the state is combining its testing teams for SNF and assisted living (along with adult day care - not ID/DD adult day - and senior centers) in an attempt to align and streamline the processes.

SNF and AL Visitation Requirements. There is understandable confusion over how visitation in SNFs and assisted living communities is affected by the two county COVID-19 color schemes, the CMS and the Ohio Public Health Advisory System (OPHAS). For SNFs only, the key factor is CMS Quality, Safety, and Oversight letter (QSO) 20-39-NH, which requires in-person visitation in certain situations. Specifically, the QSO mandates that a SNF allow visitation if the "facility has had no COVID-19 cases in the last 14 days and its county positivity rate is low or medium ...." County positivity rate refers to the CMS red category, not the OPHAS red category, which is not based on positivity but on other factors. In other words, a SNF in a red OPHAS county that is not red under the CMS criteria must allow visitation unless it had COVID-19 cases within the past 14 days. The QSO specifically states that CMS considers  failure to comply with this requirement to be a violation of certification standards.

The QSO and its mandatory visitation language does not apply to assisted living. Instead, the Department of Health (ODH) order lists 6 factors for providers to consider when deciding whether to allow in-person visitation, one of which is "[c]ase status in surrounding community ...." Unlike the QSO, the order does not establish a standard for case status or dictate how providers are to apply it. As a result, assisted living communities could use the OPHAS red category as a reason to suspend visitation, but are not required to stop visitation if a county becomes red.

While the ODH order applies to SNFs as well as assisted living communities, for SNFs it is superseded relative to mandatory visitation by the QSO. It also should be noted that both SNFs and assisted living are required by the order to permit compassionate care visits under the circumstances described in the order.

Although they are regulated by CMS, ICFs/IID are not subject to the QSO, which is specific to SNFs. ICFs should follow the Department of Developmental Disabilities visitation guidance posted on their ICF page.

More on COVID-19 Vaccinations. We learned more today about the Pharmacy Pharmacy Partnership for Long-Term Care announced by the Department of Health and Human Services (HHS) last Friday. According to both AHCA/NCAL and ANCOR, ICFs/IID are included in the program and should sign up using the Redcap survey. Other congregate care arrangements (including ID/DD group homes and independent living) also will be covered and should use the same survey.

AHCA/NCAL this afternoon held the first of a series of office hours on the resident vaccine partnership program. Today's office hours featured Ruth Link-Gelles of the Centers for Disease Control and Prevention (CDC), a key player in developing the program. The office hours format was mainly answering questions submitted by participants via chat. A few points worth noting from the exchange:

  • There is no requirement for a physician's order for the COVID-19 vaccine, per the Public Readiness and Emergency Preparedness (PREP) Act.
  • Any facility wishing to utilize its own pharmacy to administer the vaccine instead of CVS or Walgreen's still should register using the National Healthcare Safety Network (NHSN) portal or the survey, as applicable, and enter a back-up option of one of the two national chain pharmacies. CDC believes most long-term care pharmacies initially will not be able to meet the requirements for distributing the vaccine.
  • The pharmacies will bill third-party payers for administration fees. The vaccine itself is free. To the extent employees are vaccinated through this process, which should be relatively uncommon, and the facility is self-insured, it would end up paying the fees.
  • Staff member vaccinations generally will not be addressed through the partnership but through state-developed programs. Health care workers, broadly defined, are covered in Phase 1A of the federal vaccine distribution plan. Residents are in Phase 1B. If staff members are not vaccinated in Phase 1A, they can be picked up in Phase 1B.
  • The sign-up for SNFs will be in the "action items" tab of the NHSN portal, although it was not there this afternoon.
  • Registration is currently scheduled to end at 11:59 p.m. on October 29.

In related news, Bridget Harrison of the Governor's Office reported that the framework for the Ohio plan for vaccinating health care workers will be covered in a webinar that is coming soon.

NHSN Line-Level Reporting of Antigen Test Results. As we previously reported, providers conducting point-of-care antigen COVID-19 testing on-site will be required to report line-level data on those tests through one of two options: ODH or NHSN. NHSN posted to its long-term care COVID-19 module information about its option, including a printed version of the online reporting form and instructions for completing the form. Information about NHSN's webinars on the reporting process is also on the website.

SNF Value-Based Payments Coming. AHCA informed us today that based on conversations with HHS, payments to SNFs under the Provider Relief Fund for low COVID-19 case rates and mortality in September should be made this week. While the exact criteria for qualifying for these payments and the methodology for calculating them remain mysterious, HHS reportedly revealed that approximately 65% of all SNFs in the nation will receive payments for September, which should average about $40,000. Additional funding will be allocated, using the same criteria, for October, November, December, and a four-month aggregate. These payments are different from the Phase 3 General Distribution, which is available to a broad range of providers and remains open for applications through November 6.

Project ECHO Pre-Launch Webinars. Project ECHO will offer two more pre-launch webinars on strategies to prevent the spread of COVID-19 (Friday, October 23) and cohorting, cleaning, and disinfection (Thursday, October 29). These programs are free and are open to SNFs that have signed up for Project ECHO and those who are considering doing so. See this web page for more information and to register.

NCAL/AALNA Caring Together Call - COVID-19 Open Forum. The National Board of Directors and Advisory Council of the American Assisted Living Nurses Association (AALNA), in conjunction with NCAL leadership, would like to provide you with an open forum to discuss COVID-19. Please attend to share your challenges, solutions, what we as organizations can do for you, and what advice you may have for others during this unprecedented time in history and healthcare. The open forum will be held on October 27, 2020, from 3:00-4:00 p.m. Click here to register.