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October 27, 2020


OHCA Project ECHO Training. Yesterday, OHCA applied to become a hub to offer Project ECHO training to Ohio SNFs. OHCA is collaborating with academic medical centers (University of Cincinnati, MetroHealth/Case Western Reserve University, University of Toledo, and OhioHealth) to offer the 16-week program. Our goal in this collaboration is to ensure that the educational content is highly relevant for Ohio providers. OHCA members and staff will facilitate the training, which will use an innovative model with some similarities to OHCA's SNF member calls, along with expert physicians from the medical centers. The weekly, 90-minute, COVID-specific training is free, and OHCA will arrange continuing education credit for administrators and nurses. SNFs that complete the program can qualify for $6,000 stipends.

Please complete this sign-up form (yes, it's a Survey Monkey) by Monday, November 2, to participate. The form offers an option for corporations to upload facility information in bulk. If you already expressed interest in Project ECHO through another method, please register via our Survey Monkey if you wish to participate in the OHCA program. Another note: neither OHCA nor any of our partners are associated with the message from Health Services Advisory Group (HSAG) that you may have seen. HSAG is the Quality Improvement Organization for Arizona and California.

NHSN Point-of-Care Test Reporting Pathway Open. Last week, the Department of Health and Human Services (HHS) mandated that SNFs use the National Healthcare Safety Network (NHSN) pathway for reporting COVID-19 point-of-care (POC) test results at the line level. Today, NHSN announced that the pathway is open. As explained in NHSN's message below, training for the pathway is not yet available, but they provided a job aid. We hear the data entry is not difficult, but time-consuming. After the initial entry, though, the pathway saves data for each person for whom test results are entered. As explained below, using the pathway requires Secure Access Management Services (SAMS) Level 3 clearance. Assisted living communities conducting POC testing (e.g., BinaxNOW cards) are to report through the Department of Health (ODH) process instead of NHSN.

AHCA tells us that the Centers for Medicare and Medicaid Services (CMS) is exercising enforcement discretion on the line-level reporting requirements until November 20. Enforcement is through the laboratory survey process. CMS has not yet issued a survey protocol for COVID-19 testing. We understand SNFs will be required to report data for POC tests back to October 20, the date of the revised ODH lab reporting order.

Here is the text of the NHSN notice:

NHSN has released a new reporting tool as part of its Long-term Care Facility (LTCF) COVID-19 Module. On Monday, October, 19, 2020, the new tool was identified in public guidance from the U.S. Department of Health and Human Services, as the system through which Centers for Medicare and Medicaid Services (CMS)-certified long-term care facilities shall report point-of-care (POC) SARS-CoV-2 laboratory test data for both residents and staff. Once reported by the facility, NHSN will in turn report LTCF POC laboratory test data electronically to the public health agency, state or local, that has jurisdictional authority and responsibility to receive and use the facility’s data. De-identified POC laboratory test data also will be reported via existing public health reporting mechanisms to the US Department of Health and Human Services in accordance with the U.S. Coronavirus Aid, Relief, and Economic Security (CARES) Act requirements. If your state or local health department has already developed a process by which facilities report these data, please contact these public health authorities before changing the reporting process. CDC/NHSN is working with these health departments to clarify reporting requirements.

LTCF NHSN users are required to obtain Level 3 security access with Secure Access Management Services (SAMS) to report POC test data and fulfill reporting requirements. Users with Level 3 security access will have been provided a SAMS grid card. This is necessary for the reporting of Personally Identifiable Information (PII) of staff and residents via the POC reporting option. If your facility users currently have SAMS Level 1 access, the users should have been contacted by NHSN with instructions for Level 3 promotion. If you need assistance to obtain Level 3 access, please contact NHSN@cdc.gov and include in the subject line, “Enhancing Data Security.”

Trainings are being planned and information will be distributed soon. Please watch for email from NHSN. In the meantime, please check the Tables of Instructions found at https://www.cdc.gov/nhsn/ltc/covid19/index.html for guidance on the individual data elements. Please send any questions about the reporting tool to NHSN@cdc.gov and include in the subject line, “POC test reporting”.

In response to questions we have received from NHSN Users, please see the attached document which provides guidance on how to enable facility NHSN Users, besides the NHSN Facility Administrator, to edit and view Staff test result data. 

CDC is committed to working with public health partner organizations, state and local health departments, long-term care facilities, and CMS to implement this reporting. Attached is a letter sent out to public health partners on October 23, 2020 from Dr. Daniel Pollock, Chief of the Surveillance Branch at the Division of Healthcare Quality Promotion, Centers for Disease Control and Promotion.

OHCA SNF COVID-19 Reporting/Notification Fact Sheet. As requested by numerous members, OHCA updated our fact sheet detailing when and to whom SNF must report COVID-19 testing results. The updates take into account the announcements late last week that line-level reporting to NHSN is mandatory and that the former Survey Monkey for reporting results to ODH was eliminated effective Monday. The fact sheet is a "one-stop shop" for meeting your reporting obligations - until they change again, at which time we will update the fact sheet once more.

State Urges Long-Term Care Facilities to Sign Up as Vaccine Providers. Last week, ODH held a brief webinar recruiting various entities to administer COVID-19 vaccine when one becomes available. Potential vaccine providers need to enroll by submitting four forms to the state. Enrollment includes local health departments, hospitals, and "LTCF & congregate care preferred contracting parties," along with pharmacies and various other providers. The webinar did not clarify how long-term care facilities could serve as COVID-19 vaccine providers, but today Bridget Harrison of the Governor's Office, who is part of the DeWine Administration vaccine group, urged facilities to sign up.

While the requirements for providers discussed in materials on the HHS Pharmacy Partnership for Long-Term Care would preclude facilities, Ms. Harrison said other vaccines may have different requirements. By signing up, you at least would be in line in case that occurs. Enrollment is through the same OH|ID portal as used for the SNF/assisted living visitation dashboard and for electronic laboratory reporting of point-of-care test results, except the app to request in the app store after logging into OH|ID is "Vaccination Program COVID-19." Once approved, you can use the app to gain access to the four forms needed to enroll. The webinar showed a deadline of tomorrow (October 28), but we believe that is a soft deadline.

ODH Interpretations and Updates. In today's meeting with ODH survey and enforcement staff, along with Director of Health Lance Himes and Director of Aging Ursel McElroy, the state officials shared the following items of interest.

  • Holidays. ODH expects CMS to issue guidance on how facilities (presumably, SNFs) should handle the holidays in light of surging COVID-19 cases. In the meantime, the Centers for Disease Control and Prevention (CDC) released general guidance on the topic. State Ombudsman Bev Laubert commented that facilities can't stop residents from going out to visit their families.
  • CMS positivity. The CMS color rating, not the actual positivity percentage, is used to determine testing frequency.
  • Testing transportation providers. ODH's James Hodge provided the following response from CMS after he revisited the question whether transportation personnel must be tested, in light of a notice from at least one other state to the contrary:

CMS believe the requirement concerns the time spent in close quarters with the residents is what triggers transport drivers to be covered under the new nursing home testing requirement, regardless of whether they actually enter or spend time in the building.

Concerning testing, the nursing home may require the transport drivers to be tested somewhere at the expense of the transport company, or the nursing home may test them as part of their internal testing program. 

Regardless of how the testing is completed or prioritized, nursing homes are ultimately responsible under the new regulations at 42 CFR 483.80 for ensuring that testing is completed in accordance with our regulations and guidelines, as outlined in QSO 20-38. Therefore, if the nursing home requires transport staff to get tested elsewhere, the nursing home still needs to maintain documentation that testing is completed. If a transportation company refuses testing, the nursing home should find another vendor for services.

  • Contact tracing. ODH's position is SNFs should have a written policy on contact tracing because the Focused Infection Control survey guidelines require centers to investigate cases.
  • Close contact definition. For SNF regulatory purposes, ODH does not use the new CDC definition of close contact with a person with COVID-19, which applies the 15-minute standard across 24 hours.