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October 1, 2020

SNF Testing Notices. In two separate Enhanced Information Dissemination and Collection System (EDIC) notices, the state formally announced the batch upload process for the Department of Health (ODH) laboratory portal and the SNF testing schedule for the next two weeks. The batch upload process is intended to keep providers from having to reenter data for each round of testing. Please review the instructions, which have screen shots showing how to use the process, and the data dictionary, which details the information that needs to be entered into the batch upload. The schedule for October 5-18 is the first to reflect the new state-supported testing process that only covers certain buildings. The schedule was accompanied by the following text:



-       The changes were made to ensure state support could be available for routine and outbreak testing, as described in the attached webinar slides.

-       A few nursing homes switched from Quest to a state lab (Battelle, Dayton Children's, OSU, ODH, UC Health). Additional information will be sent to these facilities.

-       A NEW survey will be created and circulated via EIDC – this survey will be used going forward to update their opt in/out status, report the need for outbreak testing, and report changes in staff and resident test kit needs.

-       Additional updates will be made next week to accommodate future outbreak testing needs.

New OPHAS Map Shows More Red. Today being Thursday, the state released a new Ohio Public Health Advisory System (OPHAS) map. Four new counties (Clermont, Hamilton, Muskingum, and Richland) turned red, bringing the total to 11, while Delaware and Stark Counties went from red to orange. The main significance for SNFs is that Clermont and Hamilton Counties are green in the federal table, so the red Ohio designation means they are mismatch counties that now must test weekly instead of monthly. The OPHAS map is not mandatory for visitation, but providers are required to consider whether to continue to allow visits when the color level increases.

PRF Phase 3 Portal Opens Monday. The Department of Health and Human Services (HHS) today issued a formal announcement of the Phase 3 General Distribution from the Provider Relief Fund (PRF). The purpose of Phase 3, which will pay out $20 billion of the approximately $50 billion left in the PRF, is to address remaining COVID-19-related revenue losses and increased expenses that were not covered by previous PRF distributions. Providers who received previous General Distributions or who opened in the first quarter of 2020 are eligible for consideration under Phase 3, but they must submit applications between this coming Monday, October 5, and November 6. Eligible providers include Medicare (e.g., home health agencies, hospices, SNFs) and Medicaid (e.g., ICFs/IID, Medicaid waiver) providers as well as private-pay assisted living communities. The relatively short window for applying is because the payments to individual providers will be determined in part by how many apply. The details are not available yet, but HHS gave a general description of the data applicants must submit:
  • A provider’s change in operating revenues from patient care
  • A provider’s change in operating expenses from patient care, including expenses incurred related to coronavirus
  • Payments already received through prior Provider Relief Fund distributions.

The announcement does not specify the time period for data reporting.

Livanta Releases Waiver Application. In yesterday’s COVID-19 Update, we discussed the availability of a waiver that would enable approved providers to continue submitting faxed or hard copy medical records to Livanta after October 1, 2020. Today, Livanta released the waiver application. A Livanta representative stated that they intend to process the waivers very quickly. To qualify, a provider must show it lacks an electronic medical record system capable of securely transmitting electronic records to Livanta and must sign a memorandum of agreement (MOA) with Livanta if required to do so. The waivers will be in effect through December 31, 2020, and are intended to give providers more time to secure a direct secure messaging application. Records received through fax or hard copy from providers who do not have an approved waiver will not be accepted. Another option to meet the new requirement is to use the Livanta e-LiFT portal, which is available now. For more information on the requirements, please see links below or contact Erin Begin.

COVID-19 Impact on ICF/IID Cost Reporting. Today, the Department of Developmental Disabilities (DODD) shared Medicaid Advisory Letter (MAL) No. 647, which addresses provider questions on how to account for COVID-19-related expenses and other revenue/stimulus sources. MAL 647 is follow-up guidance to two other Medicaid Advisory Letters (MAL 644 and MAL 646) released in early August. 

President Trump Signs Continuing Resolution with Advanced/Accelerated Payment Extension. President Donald Trump today signed HR 8337, a continuing resolution to fund the federal government through December 11, after it passed the Senate last night. The legislation contains repayment relief for Medicare providers who received advanced and accelerated payments earlier this year. Most importantly, it extends both the start date and the end date for Medicare to recoup the advanced money, providing significant cash flow relief. See AHCA's summary for additional detail.

Update on CLIA Line-Level Reporting: Which Direction? OHCA today discussed with ODH their efforts to move all Ohio laboratories to electronic reporting of COVID-19 line-level data and how this activity relates to the recent announcement by the National Healthcare Safety Network (NHSN) that they will create a new pathway SNFs may use to comply with the upcoming line-level reporting requirements for their point-of-care antigen tests. ODH is reviewing a draft of the NHSN pathway while continuing final testing of the comma-separated value (CSV) file upload that Ohio labs alternatively can use to comply with the reporting requirements. 

Facilities with Clinical Laboratory Improvement Amendments (CLIA) Certificates of Waiver will need to choose from the following two options to report the required data:

  • Create a secure file transfer protocol (FTP) connection with ODH and begin populating the CSV template according to ODH's formatting instructions.
  • Use the NHSN platform when it comes on line, which NHSN expects to be October 15.

We learned from ODH that the NHSN platform unfortunately will not allow a data upload, which means providers must submit all required data elements such as name, address, sex, race, age, etc., individually for each COVID-19 test using an antigen point-of-care unit or BinaxNOW card. According to ODH, however, NHSN intends to make many of the data fields auto-populate after the data are entered the first time, which would reduce data entry for each test run. 

The state option will continue to require submitting the line-level data electronically to ODH via a CSV file, although the file can be pre-populated with most of the required data fields, then uploaded daily to ODH for tests run that day. We also learned that ODH is exploring another option for electronic data submission that would eliminate the challenges of establishing a secure FTP connection. ODH is not prepared to announce this new option today, but they hope to unveil it very soon.

At this point, we recommend all members contact NHSN immediately to upgrade their Secure Access Management Service (SAMS) access from Level 1 to Level 3 so they have the ability to use the new NHSN lab reporting pathway if they choose. Members can learn about increasing their SAMS access by clicking here and can email with the subject line “Enhancing Data Security” to begin the upgrade process. In the meantime, we encourage members to evaluate how best to comply with the line-level reporting requirement, which apparently will involve either a CSV file upload to ODH or entering data on each antigen test via the NHSN pathway. We will continue to provide more information as it becomes available.