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September 24, 2020


Director McElroy Announces Indoor Visitation in SNFs, Assisted Living. During Governor Mike DeWine's press conference today, Director of Aging Ursel McElroy announced that indoor visitation in assisted living communities and skilled nursing centers will begin October 12. Director McElroy described the yet-to-be-released indoor visitation order in some detail, much of which was consistent with our previous discussions with the Director. The state made several changes, however, mainly for consistency with the recent Centers for Medicare and Medicaid Services (CMS) guidelines. These changes include:
  • Dropping the proposed requirement to halt visitation in red and purple counties under the Ohio Public Health Advisory System. Instead, the order will retain the current facility considerations, although for SNFs, these are restricted considerably by the federal guidelines that require allowing visitation except under prescribed circumstances.
  • Dropping the proposal to require visitors to be at least 18 years of age, replacing it with a mandate that all visitors are able to comply with social distancing.
  • Expanding the compassionate care exception to visitation limitations to comport with the federal guidance.

Otherwise, the order will be similar to the description provided in our September 16 COVID-19 Update. It will include the dashboard showing individual facilities' visitation policies, which will be populated by a new required reporting item. Director McElroy told us this evening she hopes the revised order will be out tomorrow and she intends to hold a webinar on it soon.

ICF/IID Visitation. As expected, also during the news conference today, Department of Developmental Disabilities Director Jeff Davis announced publicly that indoor visitation will be allowed in ICFs/IID beginning this coming Monday, September 28. The Department of Health issued a new order entitled "Director’s Order to Limit Access to Ohio’s Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF/IID) and to Permit Visitation." The order appropriately splits visitation for ICFs out from SNFs and assisted living communities. It includes most of the requirements from the draft guidance OHCA shared with members previously. DODD also furnished an updated draft risk/benefit discussion guide that we expect will be included in the final guidance from DODD. 

Assisted Living, SNF Testing Schedules. The Department of Aging (ODA) posted an online application for the assisted living testing schedule, starting on Monday. The application allows users to search the schedule using various criteria, such as community name, and to download the full schedule as an Excel sheet. The schedule will not reflect late opt-outs, as the survey for opting in or out will remain open until tomorrow. ODA will deem non-respondents to have opted in.

Also today, the state released the SNF testing schedule for next week. This will be the last schedule for SNFs under the current state testing format. The next schedule, to be released as a draft next week, will take into account the changes in the program that take effect October 5. The state still has not published yesterday's webinar on the testing changes or any other documentation.

Aligning Assisted Living and SNF Testing. Members who operate assisted living communities and SNFs at the same location ask whether the staff from both components can test on the same schedule. The answer is no, the testing frequencies for assisted living and skilled nursing are different. It is possiblefor assisted living staff to test with SNF staff in red or yellow counties under the CMS positivity rates (or the state's so-called "mismatch" counties that are green federally but red under Ohio's system) because the SNF testing is more frequent. In those counties, the assisted living staff could test with the SNF staff every other week. The challenge is green counties, where assisted living tests more frequently. While the assisted living staff could test with the SNF staff once a month, they would need an additional test to meet the two-week frequency. We discussed this situation with Director McElroy, who will try to find a way to schedule the assisted living for state-supported testing only once a month.

SNF POC Test HRSA Coverage, Billing and Diagnoses. Since CMS released the document, “Medicare Payment for COVID-19 Viral Testing for Skilled Nursing Facility,” stating that surveillance testing (testing of residents who are asymptomatic, have not been exposed, are not undergoing outbreak testing, and not undergoing testing in order to open a facility) is not covered by Medicare and that group health insurance plans also are not required to cover the tests under these circumstances, some insurance companies have denied the point-of-care (POC) tests billed under 87426,QW. A few members inquired about Health Resources and Services Administration (HRSA) coverage for COVID-19 testing of uninsured beneficiaries, as it provides coverage for COVID-19 diagnostic testing. In its Claims Reimbursement FAQ, however, HRSA states that services not covered by traditional Medicare also are not covered under this program.   

Additionally, for coverage of diagnostic tests of uninsured individuals (such as outbreak testing), HRSA delineates diagnosis codes for testing. Below is a translation for SNF testing under CMS Quality, Safety, and Oversight letter 20-38-NHPlease also refer to the Centers for Disease Control and Prevention (CDC) COVID-19 guidelines for ICD-10 coding of confirmed COVID-19-positive encounters, which support the use of Z11.59 for screening situations.

  • Outbreak testing:
    • Z03.818 – Encounter for observation for suspected exposure to other biological agents ruled out (possible exposure to COVID-19)
    • Z20.828 – Contact with and (suspected) exposure to other viral communicable diseases (confirmed exposure to COVID-19)
  • Surveillance testing:
    • Z11.59 – Encounter for screening for other viral diseases (asymptomatic)

Abbott BinaxNOW Webinar Tomorrow for Home Health and Hospice Providers. Tomorrow, September 25, from 12:00-1:30 p.m., the Department of Health and Human Services (HHS) will host a webinar for home health and hospice agencies on the Abbott BinaxNOW™ test. The webinar will include Abbott representatives to demonstrate the training tools available and to answer questions and federal officials to discuss the program for distributing the tests. Use the following link to register for the training.

All home health and hospice agencies potentially are able to receive the Abbott cards, but only if they are eligible to perform POC COVID-19 testing under a CLIA (Clinical Laboratory Improvement Amendments) Certificate of Waiver. If you do not have a Certificate of Waiver, you will not be on the distribution list for HHS. HHS also has a testing prioritization list to determine who will receive tests through this distribution, so not all CLIA-waived agencies will receive tests.

If you are unable to attend the webinar, the session will be recorded and available for review soon. You also can access the Abbott BinaxNOW™ training portal. Training videos, modules, and frequently-asked questions (FAQs) for the BinaxNOW™ test can be accessed here. For questions regarding the test, please call Abbott Technical Services at 1-800-257-9525 or email ts.scr@abbott.com. For shipment issues or questions, email ARDxUSGovernmentSupport@abbott.com.

Are You on the List of Providers Missing Out on CRF Funding? Patrick Beatty of the Department of Medicaid (ODM) supplied a list (Excel download) of over 3,000 long-term services and supports providers who have not applied for funding under the state Coronavirus Relief Fund (CRF). In reality, there are fewer providers on the list because some are listed multiple times for different programs (e.g., PASSPORT and MyCare Ohio Waiver). According to Mr. Beatty, the list also includes providers who submitted Medicaid numbers that ODM was unable to match. We encourage all members on the list to apply now using the state's portal (scroll down to Provider Relief Payments). If you are on the list but are sure you applied, you may wish to email crfprovider@obm.ohio.gov with your Medicaid provider number (or license number for private-pay assisted living) and other identifying information. The state ultimately will reject applications with Medicaid numbers that do not match the ODM's data. Please note that the Office of Budget and Management told us if the CRF dollars are not spent by the end of the year, the state will need to return them to the federal government.