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September 16, 2020

More on Assisted Living Testing. This morning, Director of Aging Ursel McElroy shared with stakeholders details of how she plans to restart the state-supported assisted living testing program that was on pause for the last few weeks. The Director of Health order for testing assisted living staff every two weeks will remain in place, but instead of saliva testing through NovaDx, the state will use nasal-swab testing through MAKO Medical. Director McElroy said despite the change in methodology, the testing will continue to be state-supported, which in this case means at no cost to the provider or employee. As all testing will be through MAKO, each residential care facility will be assigned a day of the week for testing and will follow that day for each two-week cycle. Buildings may opt out of the state-supported testing and may secure their own tests, such as potentially the BinaxNOW cards, so long as they test at the prescribed frequency. Director McElroy said webinars on the new assisted living testing process tentatively will be held on Friday at 10:00 a.m. and 3:00 p.m., but no details were provided as of this writing.

Visitation Order Preview. Also this morning, Director McElroy gave us what is likely to be the final look at a revised visitation order that will incorporate indoor visits. The order will apply to SNFs and assisted living communities, but will not apply to ICFs/IID (see "DODD Updates," below). The order probably will include the following:
  • Indoor visitation can take place in a space that is not used for another purpose while visits are occurring and is separate from resident areas.
  • No visitation (indoor or outdoor) will be permitted in red or purple counties under the Ohio Public Health Advisory System. The federal county positivity ratings will not apply.
  • The order will require facilities to enter information about their current visitation policies into a portal that will populate a publicly-accessible dashboard.
  • Visitors will need to use facility-supplied facemasks instead of cloth face coverings.
  • The number of visitors will be limited to two at a time.
  • No one under 18 will be permitted to visit.
  • Hospice staff performing core services, beauticians, and members of the clergy will be designated as essential personnel and will not be subject to the visitation requirements.
  • The maximum length of a visit will be 30 minutes, counting only time the resident and visitor are together.
Please note that all of these items are not final and are subject to change. The effective date of the order has not been determined, but is likely to be in first half of October.

DODD Updates. Department of Developmental Disabilities (DODD) Director Jeff Davis shared today that supplemental Medicaid payments to providers of homemaker/personal care, on-site/on-call, and shared living waiver services should be made by direct deposit or check on Friday, September 18. Providers who deliver participant-directed homemaker/personal care should receive payments from MorningSun by Wednesday of next week. 

Director Davis also mentioned DODD is targeting September 28 as the date for the Department of Health (ODH) order limiting ICF/IID visitation to be revised or rescinded to allow indoor visitation in accordance with guidelines still being finalized by DODD. ICFs can begin planning for indoor visitation with draft guidance the department furnished today.  

The department also addressed outings for ICF residents. As a reminder, the ODH order limiting visitation does not restrict residents’ ability to leave the setting. The department has received frequent inquiries from families on this subject and will issue guidance asking ICFs immediately to initiate planning for resuming community activities (including work, day services, school, visits with family, etc.). The guidance will include a person-centered approach encouraging a risk-benefit analysis as one part of the decision-making process. OHCA will share the guidance as soon as it becomes available.

Finally, DODD's Kate Haller said the department will rescind previous guidance allowing flexibility with the Behavior Support Rule. Ninety-day reviews will need to be completed by December 31, 2020, and full compliance with the rule (with the flexibility for Human Rights Committees to meet virtually) will be required by January 31, 2021.

Abbott BinaxNOW Cards - It's Not an Invoice. A number of members received an email with a subject line like "PO# XXXXXXXKITS Order Confirmation" and with a pdf attachment entitled, "Order Confirmation." This document relates to the Abbott BinaxNOW cards and looks something like an invoice, especially because it has a "final amount" at the bottom. It is not an invoice. The Department of Health and Human Services (HHS) is supplying the cards to providers without charge. As AHCA's Dr. David Gifford wrote, "[w]e confirmed [with Abbott and HHS] the invoices sent out from Abbott were a mistake and do NOT need to be paid since the US Government already bought these. Abbott is exploring the reason for the mistake. Also, some members have also received communication about shipping specifications being huge pallets of 10,000 of test kits. That also is an error."

COVID-19 SNF POC Test Billing Update. OHCA continues to receive many questions relating to billing of point-of-care (POC) tests performed by a SNF. While we still are gathering information from other payers, please find a summary below of what we know now:

  • SNFs only can bill POC test claims for non-skilled residents and staff. COVID-19 testing is covered under Part A reimbursement for skilled residents.
  • The two tests available (Sofia SARS Antigen FIA from Quidel Corporation and Veritor System for Rapid Detection of SARS-CoV-2 from Becton, Dickinson and Company) both are categorized by Current Procedural Terminology (CPT) code 87426. 
  • Because SNFs that receive POC units must be Clinical Laboratory Improvement Amendments (CLIA)-waived providers, they must bill this code with a QW modifier. Please see this MLN Connects article for additional information.
  • Claims for patients who elect the hospice benefit should include the appropriate modifiers and condition codes (GW and 07, respectively) to indicate that the services are not related to hospice care. This may not be appropriate if the resident is COVID-19-positive or is symptomatic.
  • Roster billing is not permitted for this code.
  • Pricing for the POC testing code is set by CGS and does not appear on the regular fee schedules. We confirmed with CGS that their universal rate for the code is set at $35.33 per test. 
  • Some commercial insurance carriers already have set reimbursement amounts, such as Aetna, who published that they cover the code and reimburse at $45.23 per test. Aetna MyCare Medicare will cover at the Medicare reimbursement rate.
  • UnitedHealthcare stated that they do not intend to cover POC testing billed by SNF providers to commercial and Medicare Advantage plans. They will cover the code for their Institutional Special Needs Plan (I-SNP) beneficiaries.   
  • The Department of Medicaid (ODM) has not set a fee schedule for the POC test. As a result, managed Medicaid plans also cannot reimburse for this test. OHCA continues to press ODM on this matter.
  • A SNF may not bill for a specimen collection fee.

OHCA is following up with the large health plans on coverage and payment status. If you have any questions or issues relating to POC billing, please contact Erin Begin.

Another Outbreak Testing Clarification. In last night's COVID-19 Update, we included an excerpt from an AHCA frequently-asked questions document on the Centers for Medicare and Medicaid Services testing requirements that included a statement that the following scenario triggers the outbreak testing requirement: "A resident who was admitted from the hospital and had a test obtained in the facility three days after admission and it tests positive." This statement is true only if the patient was not placed in transmission-based precautions. According to applicable Centers for Disease Control and Prevention (CDC) guidance, positive tests among "[r]esidents who were placed into Transmission-Based Precautions on admission and developed SARS-CoV-2 infection within 14 days after admission" are not considered "nursing home onset" and thus do not trigger an outbreak. CDC guidelines generally require transmission-based precautions for all new admissions, so unless a SNF fails to follow these guidelines, a positive test in a newly-admitted patient would not trigger outbreak procedures.

Adult Day and Senior Center Update. The Department of Aging (ODA) is partnering with MAKO Medical to provide state-supported testing services for adult day service (ADS) and senior center facilities. Through this program, ADS and senior center facilities will receive support with testing including free training, access to test kits, lab capacity, and testing. Please visit this website to review additional information, including webinar slides from September 11, 2020, testing information, and more.

ODA and MAKO Medical will host another webinar to discuss the logistics of testing on Friday, September 18, from 10:30 to 11:30 a.m. Register here for this webinar.