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October 8, 2020

SNF/AL Visitation Order Finally Posted. Today, two weeks after Governor DeWine announced the new order for indoor visitation in SNFs and assisted living communities and only four days before it takes effect, the Department of Health (ODH) posted the order. Although there are some references to "nursing homes" in parts of the order, all provisions appear to apply to both SNFs and licensed residential care facilities. The order does not apply to ICFs/IID. On first review, the order does not contain any surprises and generally parallels what we previously reported. There is additional language on compassionate care visits that places some limits on these visits, which otherwise are broadened as provided in the federal definition. Please review the order carefully so you can adjust your visitation policy to comply. The effective date is still Monday, October 12. The order requires providers to populate the state's visitation dashboard, which is not yet available. The effective date of the dashboard requirement is October 19.

Remember that for SNFs only, Centers for Medicare and Medicaid Services (CMS) Quality, Safety, and Oversight letter (QSO) 20-39-NH also governs visitation. In developing their visitation policies, SNFs need to comply with both the QSO and the order. For instance, the ODH order does not require SNFs to allow visitation, but the QSO does, except when the facility had COVID-19 cases in the last 14 days or is in a high-prevalence county. Please feel free to contact OHCA for assistance in sorting out the federal and state requirements.

COVID-19 Spread Continues in Ohio. The new Ohio Public Health Advisory System (OPHAS) map released today shows a concerning picture. In addition to 18 red counties, nearly all others are orange. Only 12 yellow counties remain. This causes several more counties to slip into mismatch status, requiring weekly routine testing. We updated our version of the CMS positivity table to include the changes in OPHAS.

Next Week's SNF Testing Schedule, New Survey Monkey. The state posted the following message on the Enhanced Information Dissemination and Collection System (EIDC) this afternoon.

Please find an updated schedule for state supported NF testing for specimen collection (swabbing) dates 10/12 to 10/18 here 

The schedule linked above is based on data pulled from CMS and the Ohio Public Health Advisory System Data on 10/5/20. The State will pull data to update county positivity rates/colors again on 10/19/20.

Please carefully review the updated schedule on the FIRST TAB.

  • Facilities that are testing this week (10/5 to 10/11) are not listed on this tab unless they are located in Athens, Putnam or Richland counties (CMS red counties) [OHCA note: Athens is not currently a CMS red county]. They will be listed on future schedules if still eligible for state support after 10/18.
  • Facilities were ADDED to the schedule for 10/12 to 10/18 due to county positivity rate changes resulting in start of state supported testing and due to new reports of outbreaks.
  • Facilities were REMOVED from the schedule for 10/12 to 10/18 due reports of outbreaks ending (or no outbreak at all) in counties where state support is not available for routine testing

Information about required routine testing frequency (per CMS and state requirements) by county, as well as state-supported testing frequency available by county, can be found on the SECOND TAB.

Starting today, please use this new electronic survey, to provide updates for your facility for state supported regarding ANY TIME you need to report ANY of the following changes:

  • Change in outbreak status (start state supported testing for a new outbreak, end state supported testing after the conclusion of an outbreak)
  • Change in need for state support (opt-in/opt-out)
  • Change in need for supplies

State Repayment of Self-Insured SNFs to Testing Costs. For some time, the state has assured SNFs that provide health care coverage to their employees through a self-insurance plan that the state would cover the cost of state-supported testing. This applies to testing after the initial round conducted by the National Guard. The state, however, still has not provided a mechanism to reimburse these costs. OHCA is working with them on this issue. We hope to have more to share soon, but in the meantime, we have the following suggestions for preparing:

  • Obtain from your third-party administrator an itemized list of all COVID-19 test claims paid to a laboratory for a polymerase chain reaction (PCR) test after the initial National Guard testing.
  • Remove any claims for testing symptomatic employees, leaving only those for the state-supported surveillance testing.
  • Remove any claims for tests conducted during any period when the SNF opted out of state-supported testing, whether or not the tests were performed by same lab the center used under the state program.
  • Remove any claims for CMS-mandated that are not state-supported. State support currently is available weekly for centers that must test twice a week under the CMS guidelines and bi-weekly for centers that must test weekly under the CMS routine testing guidelines, the Ohio mismatch county requirement, or the CMS outbreak requirement. No state support is available for centers that test monthly under the CMS guidelines.
  • Continue to add paid claims weekly until the state announces how it will reimburse for them.

CMS Chicago Webinar on PRF Phase 3. We previously reported that AHCA/NCAL added coverage of the Phase 3 General Distribution that opened Monday to its scheduled webinar tomorrow at 3:00 p.m. on Provider Relief Fund (PRF) reporting requirements. Alternatively, you could view a webinar limited to Phase 3 that CMS Chicago is offering at the same time. CMS Chicago added:

Providers are encouraged to apply for the latest round of Provider Relief Fund (PRF) support. Applications will be considered regardless of whether your organization was previously eligible for, applied for, received, accepted, or rejected prior PRF payments. For this newest phase, funding will be allocated to providers based on assessed financial losses and changes in operating expenses caused by COVID-19.  For more information about the Phase 3-General Distribution, please visit the Provider Relief Fund webpage. Apply through November 6. 

CMS Issues Guidance on Repaying Advanced and Accelerated Medicare Payments. In a beneficial move for Medicare providers who took advantage of the opportunity to receive accelerated and advanced payments earlier this year, Congress deferred the repayment obligation in the Continuing Appropriations Act, 2021 and Other Extensions Act. Today, CMS announced the Congressional action and issued a revised fact sheet on advanced and accelerated payments reflecting the deferral, which they call an Extended Repayment Schedule (ERS). According to the Act, an ERS is available upon request of the provider. CMS wrote in the fact sheet:

Extended Repayment Schedule (ERS) is a statutorily authorized debt installment payment schedule, which allows a provider or supplier experiencing financial hardship to pay debts over the course of three years. This can be extended to as many as five years, where certain extreme hardship criteria are met. Providers and suppliers are able to request ERSs after demand letters are issued. Providers and suppliers should contact their MAC for information on how to request an ERS.

In the announcement, CMS stated, "[t]o 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. CMS will be communicating with each provider and supplier in the coming weeks as to the repayment terms and amounts owed as applicable for any accelerated or advance payment issued."

COVID-19 Waste Management Guidance. ODH's Bureau of Infectious Disease provided the following recommendations for waste management relative to COVID-19.

COVID-19 is not a Category A infectious substance. 

Waste Management

Should medical waste or general waste from healthcare facilities treating PUIs and patients with confirmed COVID-19 be handled any differently or need any additional disinfection?

Medical waste (trash) coming from healthcare facilities treating COVID-2019 patients is no different than waste coming from facilities without COVID-19 patients. CDC’s guidance states that management of laundry, food service utensils, and medical waste should be performed in accordance with routine procedures. There is no evidence to suggest that facility waste needs any additional disinfection.

More guidance about environmental infection control is available in section 7 of CDC’s Interim Infection Prevention and Control Recommendations for Patients with Confirmed COVID-19 or Persons Under Investigation for COVID-19 in Healthcare Settings.


Medical facilities and institutions generating potentially infectious waste

According to the Centers for Disease Control and Prevention, there is no evidence to suggest that waste associated with COVID-19 needs any additional disinfection prior to disposal. Medical care facilities and other institutions that generate potentially infectious wastes should continue to use standard precautions to prevent transmittal of disease. These facilities should already be aware of their generation of wastes subject to special packaging, labeling, transportation, or treatment requirements.

Typically, single-use PPE generated as a result of routine activities at these locations may be disposed of in the regular solid waste stream (e.g., municipal trash). Used PPE related to COVID-19 is no different unless it becomes saturated with body fluids that can flow freely or be squeezed from the PPE. Applicable facilities should use their standard protocols to determine if used PPE is subject to any special handling requirements or if it may go into the regular solid waste stream.