ODH transparency order still not available. The Department of Health still has not posted the order, announced yesterday, that will require long-term care facilities to notify residents, families, and staff members if they have a confirmed positive COVID-19 case and will require public disclosure of those facilities. That also means the many questions that OHCA members have about the order cannot be answered yet, although OHCA learned that the order is expected to cover SNFs, residential care facilities, and ICFs/IID. We believe the order will be released tomorrow.
PPE options for OHCA members. In our continuing effort to vet vendors claiming to sell personal protective equipment (PPE) during the COVID-19 emergency, OHCA believes we identified two trustworthy sources.
- Techman Sales tells us they currently have 70,000 KN95 respirators at their warehouse in Mansfield and anticipate receiving surgical masks next week. Pricing and contact information can be found here.
- Accurate Healthcare, an OHCA associate member, informed us that they have 250,000 3-ply earloop masks and 5,000 generic N95s in stock. Masks are selling for $0.96 and N95s for $8.25. Contact James Hobbs at jhobbs@accuratehealthcare.com or Andrea Armour at aarmour@accuratehealthcare.com for more information. Andrea also can be reached at 931-703-4848.
Ohio submits 1135 waiver and Appendix K. Albeit trailing the rest of the country, Governor Mike DeWine announced today in his press conference that the Department of Medicaid (ODM) submitted an application for an 1135 waiver and an Appendix K request to the Centers for Medicare and Medicaid Services (CMS). These authorities allow CMS to waive federal Medicaid regulatory provisions identified by the state. 1135 waivers apply to Medicaid state plan services, while Appendix K applies to 1915(c) waiver services. We just received the documents ODM filed, so we have not yet had an opportunity to review them in depth. Look for more information in tomorrow's update. If CMS approves the waivers, they will be retroactive to March 1, 2020.
ODM expands telehealth for home health and hospice, provides clarification for SNFs. Yesterday, the Department of Medicaid (ODM) released guidance adding home health and hospice agencies as eligible billing entities for telehealth services. ODM expanded the definition of telehealth during the emergency to include telephone calls, fax, email, and other communication methods that may not have audio and video elements. Hospice may bill for routine home care, continuous home care, or room and board as well as service intensity add-on (SIA) codes. Home health agencies may bill for services delivered via telehealth when clinically appropriate. In ODM's frequently asked questions (FAQ) document, they define this as a service that does not require hands-on care, such as supervision of a home health aide and assistance that only requires verbal cueing. ODM also allows home health and hospice face-to-face encounter visits to be performed by telehealth. Providers should consult the updated telehealth billing guidance for instructions on claim submission. These rules only apply to Medicaid, MyCare Ohio Medicaid, and managed Medicaid beneficiaries, effective April 15, 2020.
While ODM did not add SNFs to the list of eligible billing entities for telehealth, they reminded providers that physicians and other eligible practitioners may bill Medicaid services supplied through telehealth in a SNF. Like other Medicaid therapy services, telehealth therapy is bundled into the SNF's Medicaid per diem. Costs incurred are reported on the SNF's Medicaid cost report.
CMS confirms Medicaid eligibility issues. CMS posted a frequently-asked questions document on Medicaid implications of the Families First Coronavirus Recovery Act and the Coronavirus Aid, Relief, and Economic Security (CARES) Act that confirms Medicaid beneficiaries cannot lose eligibility during the COVID-19 emergency even if they otherwise would not meet eligibility requirements (see questions 25-35). The document also confirms that the CARES Act stimulus payment (Recovery Rebate) does not count as income to a Medicaid beneficiary and also does not count as a resource for 12 months after receipt (see question 54).
DODD DSP recuitment toolkit. The Department of Developmental Disabilities created a toolkit with materials providers can use to help recruit direct support professionals (DSPs), including a video that directs potential DSPs to search for job openings on OhioMeansJobs.com.
Detail on payroll tax deferral. Under the CARES Act, employers can defer the employer portion of the Social Security payroll tax until 2021-2022. One of the requirements is that if the employer takes out a loan that ends up being converted into a grant under the Payroll Protection Program (PPP), also a part of the CARES Act, they are not eligible for the payroll tax deferral. A nuance of this prohibition, explained in the Internal Revenue Service guidance on payroll tax deferral, is that any taxes deferred before the lending institution approves converting a PPP loan into a grant remain deferred. Only employer Social Security payroll taxes after approval of the grant conversion cannot be deferred.
NAHC infection prevention Q&A. NAHC partnered with Mary McGoldrick to develop a question-and-answer-document on how home-based care providers can operate safely during the COVID-19 crisis. The document covers strategies to prevent transmission, common infection control breaches during care, best practices for managing limited PPE, and caring for a COVID-19-positive patient in the home.
FCC telehealth funding for non-profit/governmental SNFs. Last Friday, the Federal Communications Commission (FCC) announced launch of the COVID-19 Telehealth Program with $200 million in funding to help non-profit and publicly operated healthcare providers, including SNFs, purchase telehealth goods and services. Please see the following resources for more information:
Questions about the application process can be emailed to emergencytelehealthsupport@fcc.gov.
Tips for dementia care during the COVID-19 emergency. OHCA collaborated with the Alzheimer’s Association (AA) to develop two dementia care tools, one for long-term care communities and one for home-based services. The tool for long-term care communities uses the verbiage assisted living, as that is how AA nationally refers to long-term care. It includes tips for caregivers of individuals with dementia in assisted living and suggested options for communicating with their loved ones in lieu of visits. These suggestions are, of course, up to the facility, and family members are encouraged to reach out to the facility directly to discuss.
The tool for home-based services provides families and caregivers tips for supporting persons living with dementia who receive home-based services. This tool can assist with educating and empowering them to ask the right questions and to advocate for the safety of the person served.