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October 20, 2020

State's Announcement of New SNF Testing Plan. The Department of Health (ODH) sent out a notice today on the Enhanced Information Dissemination and Collection System (EIDC) about the new testing process for SNFs to take effect Monday, October 26. The notice does not provide the level of detail we received yesterday from the DeWine Administration testing team, but it does refer to a video to be posted tomorrow that will explain further. This video apparently takes the place of the webinar and updated Survey Monkey mentioned to us yesterday. The notice states:

Dear Nursing Home Administrators, Medical Directors, Directors of Nursing, and other staff responsible for COVID-19 testing of staff and residents; Local hospitals that partner with nursing homes to plan for and respond to COVID-19; Local health departments


The COVID-19 pandemic continues to evolve and Ohio, much like the rest of the nation, is experiencing a surge in cases. Last week, new health data found that 29 counties currently have a very high risk of exposure and spread. Moreover, Ohio currently has 70 counties that are either red or high incidence. That's 10 million Ohioans or 85 percent of the population, living in an area with a high risk of community transmission. One tool we have to limit the spread of COVID-19 is testing and we must continually assess and adjust our testing strategy to protect all Ohioans, including our most vulnerable.

Updates to the Ohio Department of Health guidelines for the testing of the residents and staff of all nursing homes will become effective October 26, 2020, and minimally include weekly testing for all nursing homes.  In addition to new guidelines, our processes have improved in an effort to increase compliance, decrease risks, and promote data uniformity.

The state-supported testing will:

•       Implement a weekly testing program for all nursing homes for routine and outbreak testing
•       Support compliance with CMS testing requirements
•       Expand testing to include rapid antigen tests and PCR tests
•       Align testing for nursing homes that share campuses with other facilities (e.g., assisted living
•       Optimize scheduling for predictability and consistency
•       Streamline reporting requirements
•       Centralize state support for long-term care testing

Action Steps

An informational video of the state's updated testing guidelines for nursing homes and new state-supported testing options will be published Wednesday, October 21, 2020 at Please reserve time to familiarize yourself with this new information before October 26, 2020. This video will equip you with new information regarding scheduling, supplies, reporting, and much more. At the completion, you will be asked to indicate the level of state-supported testing needed for your facility.

New CMS Positivity Rates for SNF Testing. The Centers for Medicare and Medicaid Services (CMS) released this week's county positivity ratings, as used for SNF testing and visitation. Ohio is down to only two red counties, Butler and Putnam. This week we again added the Ohio Public Health Advisory System (OPHAS) color ratings to the table to identify mismatch counties, but because of the switch to statewide weekly testing (except CMS red counties) next week, this will be the last time the information will be needed. 

Visitation Dashboard Live. Today, in conjunction with Governor Mike DeWine's press conference, the state turned on the visitation dashboard for SNFs and assisted living communities. As of this writing, 451 assisted livings and 641 SNFs had entered data into the dashboard. There also is a detail-level page showing each facility's accommodations for visiting. ODH's Rebecca Sandholdt told us the portal for facilities to enter data includes a feature that allows the provider to indicate visitation is suspended because, for example, COVID-19 is present in the building. She added that this feature would hide, but not erase, the visitation detail.

NHSN Reporting Deficiencies. Gregg Brandush of CMS Chicago sent a message to the region's provider associations notifying them of an increase in the number of SNFs that failed to submit the required test result data to the National Healthcare Safety Network (NHSN), resulting in an automatic civil money penalty (CMP). These providers should have received notices of the CMPs yesterday, but we have the list of Ohio centers if you wish to check. Mr. Brandush wrote:

I hope you are all staying safe in this latest national surge in COVID cases. I know all of you are really busy keeping residents safe, but I wanted to take a brief moment to let you know about an increase we are seeing in the numbers of providers that are not reporting their COVID testing data to the CDC as required. We were down as low as 0.8% of providers not reporting a couple of weeks ago, but last week we were up to over 4% of providers not reporting. This is 139 providers that will be receiving an easily avoidable CMP.

Could you please send a reminder to your members that these reporting requirements remain in place and that they should be checking their letters in CASPER and reporting every week?

COVID-19 Vaccination Update. Ohio's interim draft vaccination plan saw the light of day today, although the official posting apparently will be tomorrow. The state already submitted the plan to the Centers for Disease Control and Prevention (CDC). There are some concerning aspects of the draft plan, as it does not include OHCA or other organizations representing long-term services and supports providers as stakeholders for Phase 1A (high-risk healthcare workers) and places "[p]eople in group homes for individuals with physical or mental disabilities" into Phase 2. In both respects, the state plan appears to conflict with the Department of Health and Human Services Pharmacy Partnership for Long-Term Care, which includes group home residents in Phase 1B along with SNF, assisted living, and other congregate facility residents and which intimates that workers in all of those facilities are in Phase 1A.

The state is offering a webinar tomorrow on its plan, which is primarily aimed at vaccine providers, but may be of interest if you wish to learn more about this initiative. You may register for the webinar at this link.

Also relative to the Pharmacy Partnership, our reporting yesterday about the registration form's location on the NHSN reporting portal was incorrect. The form appears as a pop-up when you first log into the reporting section. We recommend all facility members sign up before the deadline of October 29. The registration is non-binding, and you can back out later if you wish to use another method to get residents vaccinated.

Important ODH Interpretations. In a meeting today with provider associations, ODH shared several interpretations that apply to different provider types, but are particularly important for assisted living communities and ICFs/IID.

  • Assisted living communities and ICFs/IID are subject to CDC and (in the case of ICFs) CMS guidelines that are specifically for them, but not to guidance specific to SNFs. For instance, assisted living communities and ICFs are not subject to the requirement to quarantine all new admissions or readmissions or to the requirement that staff wear eye protection in purple, red, or orange counties under OPHAS, both of which apply to SNFs. Instead, they are to take precautions for new admissions/readmissions appropriate to the individual's and the facility's circumstances, as determined in a person-centered way. Eye protection is required when the facility experiences a COVID-19 case, not dependent on the county color.
  • Also relative to eye protection, ODH clarified that it is required only in resident care areas, which include any place where a resident may receive care, not just their room. This interpretation applies to all regulated facilties, including SNFs.
  • COVID-19-positive residents of SNFs and assisted living communities can receive compassionate care visits if the visitor wears the necessary personal protective equipment (PPE) to be in a room with someone who has COVID-19. Facilities can have reasonable policies to limit the number of visitors in this situation, but not to restrict vistiation unduly.
  • There is no specific limit on the number of people who can be in a dining or activities room, so long as social distancing is maintained.
  • Assisted and independent living residents can participate in the same activities, again with social distancing. 
  • A person moving from an assisted living community to a SNF (or vice versa) in the same building does not require restarting a quarantine period.

Updated ODH Laboratory Reporting Order. Interim Director of Health Lance Himes today posted an amended order on laboratory reporting. This is relevant to long-term services and supports providers who perform on-site antigen testing, because they are considered laboratories operating under Clinical Laboratory Improvement Amendments (CLIA) Certificates of Waiver. Effective today, the new order requires electronic, line-level reporting of the results of all COVID-19 tests a lab performs. Providers have a choice of reporting through the ODH Electronic Laboratory Reporting program or through NHSN (see references to point-of-care reporting). You should keep detailed records of any antigen testing done starting today until you have the ability to report using one of these methods.  

AHCA/NCAL PPE Supplier List. AHCA/NCAL continues to update its list of PPE suppliers. The list includes descriptions of the suppliers and contact information. It may prove helpful is you are having difficulty obtaining a particular type of PPE.