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September 30, 2020

Livanta Requirement: What to Do if You Don’t Have Direct Secure Messaging. Starting tomorrow, October 1, the direct secure messaging requirement from Livanta takes effect. The short notice of the requirement left many OHCA members scrambling. If you reached out to your electronic medical record (EMR) vendor, you likely were told that implementing direct secure messaging requires a waiting period. If your EMR does not support direct secure messaging, Livanta provided OHCA with a list of Health Information Service Providers (HISPs) that can facilitate direct secure messaging. Please contact Erin Begin if you would like to review the list. 

OHCA also obtained the following clarifications to help members meet Livanta's requirement until direct secure messaging connections are made, and after:

The waiver: If you received Livanta's notice last night, you likely know there is an option to obtain a waiver allowing you to delay implementing the electronic documentation submission requirement. This option is a bit misleading. For one, the waiver is not yet available (it will be posted here once available). Secondly, the waiver is only valid through December 31, 2020. Additionally, the waiver must be approved under the following criteria:

a.  The provider can show it lacks an electronic medical record system capable of securely transmitting electronic records to Livanta; and

b.  The organization signs a memorandum of agreement (MOA) with Livanta if required to do so. Click here for more information on MOAs.

Livanta will process waivers on a case-by-case basis, so if you are looking for a quick fix, this is not your best option.

Livanta File Transfer Portal: Under this option, providers submit medical records through the e-LiFT portal. Before uploading a medical record, the provider must enter the case number and a unique identifier supplied on the medical record request. Accepted file types include PDF. OHCA is awaiting clarification on limitations related to the file size and number of attachments allowed for each submission.

While provider submissions are required electronically, the request for medical records from Livanta will still be sent through fax. 

Here are a couple additional details regarding electronic submissions:

Direct Secure Messaging: If you already have direct secure messaging through your EMR or another vendor, you can send the medical records to for discharge and service termination appeals and for quality of care complaints.

Reimbursement: If you submit medical records electronically (either through direct secure messaging or the e-LiFT portal), Livanta will reimburse you at a flat rate of $3.00 per patient record in the next billing cycle. A patient record is defined as “all patient care data and other pertinent data or information relating to care or services provided to an individual patient in the possession of the provider or practitioner, as requested by a QIO for the purpose of performing one or more QIO functions.”  Additionally, duplicate copies or fragmented submissions for one episode of care will not be reimbursed individually. Only providers will be paid, and invoices will not be acknowledged. For additional information on reimbursement, please see the Livanta Postage and Pages Reimbursement Protocols webpage.

Unpublished CMS SNF Testing Change Disrupts Ohio Schedule. It is our understanding from a state source that yesterday, when the Centers for Medicare and Medicaid Services (CMS) announced changes made two weeks ago to the formula it uses to assign county positivity ratings, CMS also changed the impact on testing frequency when a county moves from a higher to a lower positivity level. According to Quality, Safety, and Oversight letter (QSO) 20-38-NH, SNFs in such a county must continue to conduct routine staff testing at the higher frequency for 14 days after the color changes. We are told that CMS removed that requirement, allowing providers to apply the lower frequency - although the announcement does not state this clearly. The only clue is in the positivity spreadsheet itself, where after explaining the calculation changes, CMS wrote, "[n]ursing homes may set their testing frequency based on the color-coded reassigned positivity classification."

As a result of this change, the state is redoing their state-supported testing schedule for next week to account for counties that moved to lower positivity ratings: "I wanted to inform all of you that given some changes made by CMS and the county positivity ratings the schedule for Nursing Home testing will be released tomorrow; however, testing will still occur beginning 10/5/2020."

ODH Lab Portal News. Although we have not seen an Enhanced Information Dissemination and Collection System (EIDC) notice on it, we believe that a production version of changes to the ODH lab portal for SNF testing will go into production tomorrow and will be available for your use. These changes respond to widespread concerns about the need continually to reenter data into the portal for each round of testing. If you gain access to the portal tomorrow, please be sure to check the revised testing schedule discussed above. Some centers will test on different days than expected because of the change.

Error in Eye Protection Piece. In last night's COVID-19 Update, we erroneously identified the color of the counties where Department of Health (ODH) surveyors expect SNF staff to wear eye protection (face shield or goggles). It is orange, red, and purple, not yellow. As a side note, the relevant Centers for Disease Control and Prevention (CDC) guidelines specify that staff should "[w]ear eye protection in addition to their facemask to ensure the eyes, nose, and mouth are all protected from exposure to respiratory secretions during patient care encounters." The words "during direct patient care encounters" show that eye protection is required while providing care, not anywhere in the facility.

PAWS Reinstatement, Risk/Benefit Guide. Today, the Department of Developmental Disabilities’ (DODD's) Debbie Hoffine announced that the department will reinstate Prior Authorization of Waiver Services (PAWS) edits for claims processing in early November (expected date of November 5). While DODD removed the edit during the pandemic, providers still were required to receive county board authorization for the services they provide (via email, phone call, etc.). While DODD does not require county boards to reconcile authorizations with claims billed for dates of service before the edit is reinstated, some county boards are doing so. Providers should work with their county board(s) to determine what actions will be required as the PAWS edits return. 

In addition, DODD’s Kim Hauck clarified that their revised risk/benefit discussion guide applies not only to planning related to ICF resident outings but also replaces the previous version used to help decide whether to return to adult day services (for both ICF and waiver recipients). 

FREE Leadership Coaching for DD Providers. OHCA partnered with other DD organizations to provide free leadership coaching webinars for our DD provider members. The sessions will be led by consultant Jason Barger and will take place over three Thursdays (October 15, November 12, and December 17) from 4:00-5:00 p.m. OHCA recognizes that many leaders in DD services have had more asked from them now during the COVID-19 pandemic than any other time during their careers. These free leadership coaching forums will support DD leaders in navigating through change. For more information and to register for these FREE webinars, please see the educational brochure