Proposed SNF payment rule. No, it is not a COVID-19 story per se, but coronavirus likely played a part in shaping the Centers for Medicare and Medicaid Services' (CMS's) proposed Federal Fiscal Year 2021 payment rule for SNFs. The proposed rule is as clean is it could be, with a full 2.3% market basket, no budget neutrality adjustments to the Patient-Driven Payment Model, and no changes to the Quality Reporting Program or Value-Based Purchasing. CMS does propose some rather esoteric ICD-10 coding refinements. They estimate the value of the market-basket adjustment to be $784 million nationwide. For more detail, see AHCA's summary.

AHCA guidance on reporting COVID-19 positives. Responding to significant media coverage in the past two days and the likelihood of CMS action, AHCA issued guidance calling for providers to report positive COVID-19 test results to the state health department and state survey agency (in Ohio, one and the same). In Ohio, because state rules require reporting to local health departments, which in turn report to the state, we believe providers would comply with the AHCA guidance by reporting to the local as an agent of the state. The other option would be reporting directly to CMS, but in discussion with state executives, AHCA learned that most states have reporting requirements already, so it would make more sense for CMS to obtain the information from the states instead of creating duplicative reporting by providers.

Learn from someone who has been there! OHCA ID/DD members are invited to join a call hosted by the Department of Developmental Disabilities on Monday, April 13, 2020, at 3:00 p.m. OHCA ID/DD Board member Becky Sharp from Columbus Center for Human Services will share her experiences as a provider who has had several residents test positive for COVID-19. To join the call, dial (614) 721-2972 and use Conference ID 52410594.

Emergency Medicaid managed care changes. The Department of Medicaid (ODM) amended its provider agreements with Medicaid managed care plans on an emergency basis to relax various requirements. The changes mainly have to do with prior authorization and other restrictions on providers and members, including mandating that all plans temporarily allow 365 days for timely filing. See ODM's bulletin for a list of the specific relief items. ODM wrote that it is implementing similar changes in fee-for-service Medicaid.

Practical advice. A couple of items for today.

• In the event of a positive COVID-19 case, there is no substitute for timely, clear, and consistent communication with your two most important audiences: your staff and the people you serve and their families/guardians. Along with the local health department, they should be the first to know. Give yourself an opportunity to calm their fears before they hear through the grapevine and add anger to fear. There are multiple examples of families, in particular, who claim not to have been informed going to the news media with their complaints.

• Be extra careful with agency staff. Anyone who works in multiple long-term services and supports settings - agency being an obvious example - has a much greater chance of being a vector for COVID-19. An agency may not be sufficiently diligent about identifying a temporary's possible exposure to a COVID-19-positive patient or co-worker at another location. Your extra investigation could save lives.