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April 16, 2020

ODH list of facilities with COVID-19.The Department of Health (ODH) posted their list of facilities that they believe have COVID-19 positive or probable cases. The list, which includes SNFs, residential care facilities (RCFs), and residential facilities licensed by the Department of Developmental Disabilities (DODD), shows numbers of cases for each facility listed. This morning, we immediately began to hear from members about erroneous information on the list, such as facilities that did not have cases being listed and wrong numbers of cases. This obviously means families and other members of the public receive inaccurate information about those buildings. In addition, the list contains at least licensed developmental disabilities provider that did not have any cases in their licensed setting, but did have one case in a non-licensed setting.

We notified ODH of all such errors that members brought to our attention. We also asked ODH to take down the list until the data have been verified, but that has not happened as of this writing. Other issues with the list are no distinction between staff cases and resident cases, cases that have resolved not removed (although there is a disclaimer about this at the top of the page), no distinction between a SNF and a RCF in the same building, and in at least one example, a contractor who was not a resident or staff member included. We will continue to work to cleanse the list.

OHCA advertisement recognizing caregivers. Beginning tomorrow, OHCA will begin running an advertisement that salutes the heroes of long-term services and supports who are standing strong and providing care for the people who rely on them to be there every day. It will appear in selected broadcast and cable markets and digitally. We hope it will rally support from the public and our state's leadership at this difficult time. We encourage members to distribute the ad widely via social media and email to raise up the hard-working people who continue to serve despite COVID-19.

Palmetto GBA Guidance on RCD Pause. Claims submitted on or after March 29, 2020, are not required to go through the Review Choice Demonstration (RCD) process during the COVID-19 public health emergency (PHE). Palmetto GBA provided guidance stating that they will process claims submitted prior to the emergency period under normal claims processing requirements. If you are in Choice #1 and decide not to submit any Pre-Claim Review (PCR) requests during the emergency, you will not be subject to the 25% reduction and will not receive any pre-payment Additional Documentation Requests (ADRs). After the PHE ends, Palmetto GBA will conduct post-payment review on claims subject to the demonstration that were billed and paid during the pause. You may continue submitting your PCR requests as normal, and you will continue to receive decision letters and Unique Tracking Numbers (UTNs) to attach to your claims. These claims will be excluded from further review. All claims for which you received a UTN must have it on the claim form to avoid denial. Providers who selected Post-Payment Review will not receive any ADRs during the pause. Any claims subject to the demonstration will be reviewed after the PHE ends.

CARES Act funding attestation. Providers who received the first tranche of Coronavirus Aid, Relief, and Economic Security Act funding must attest receipt of the money and agreement to the terms and conditions. The Department of Health and Human Services (HHS) posted a portal for the attestation. They also clarified that, for purposes of eligibility for the funding, "[c]are does not have to be specific to treating COVID-19. HHS broadly views every patient as a possible case of COVID-19."

ODM to amend 1135 waiver. State Medicaid Director Maureen Corcoran confirmed this morning that the state intended to file an amendment to their original 1135 waiver request that was filed Tuesday to include ICF/IID regulatory items inadvertently omitted.

Q&A call on Pre-Surge Planning Toolkit. The Departments of Health, Medicaid, and Aging will hold an all-provider question-and-answer call tomorrow from 3:30-5:00 p.m. on the state's recently published Long-Term Services and Supports Pre-Surge Planning Toolkit. Go to this link to participate in the call. If you have questions on the toolkit that you would like to be covered on the call, please email them to

DODD webinar on Pre-Surge Planning Toolkit. DODD is offering two distinct webinars on the same toolkit as above, but from the developmental disabilities perspective. The first webinar, for community settings (ICFs or other licensed facilities not capable of serving a COVID-19 patient), will be held on Tuesday, April 21, 2020 from 10:00–11:00 a.m., with registration found here. The second webinar, for congregate care settings (facilities capable of serving a COVID-19 patient), will be held on Tuesday April 21, 2020, from 1:30-2:30 p.m. with registration available here.

Health issues another rule waiver. ODH issued another rule waiver today that pertains to SNFs, specifically to nurse aide training. The waiver does not address the 4-month time limit for using a person to perform nurse aide duties without completing training and testing, as did the CMS blanket waiver on this subject. Instead, it removes the time frame for making up missed classes, allows classroom training to provided online, and expands where clinical training may be done. Health explained that they did not waive the 4-month period because it is in statute. OHCA's view is a state waiver is not needed anyway, because House Bill (HB) 197 extended all statutory time limits during the COVID-19 emergency, including the 4 months for nurse aides. Many members have taken advantage of this legislation to fill critically needed staff positions during the emergency using the AHCA temporary nurse aide course. Although ODH has not yet put their position in writing, it appears that they disagree with our interpretation of HB 197's impact.

CareSource authorization waivers. For CareSource Medicaid beneficiaries (not MyCare Ohio, Marketplace or Medicare Advantage), CareSource will immediately follow the Department of Medicaid direction on relaxing prior authorization (PA) requirements. Please see the full notice for more detail. The waived PA requirements include:

  • First two weeks of home health services.
  • Private duty nursing for 90 days.
  • New admissions to SNFs (level of care requirements still apply).

HCAOA recommendations for home care workers with no exposure. The Home Care Association of America (HCAOA) released a protocol for home care agencies that have no known exposures to the COVID-19 virus. Included is a guide with steps for agency preparedness, caregiver guidance, and client awareness. The guidance is based on Centers for Disease Control and Prevention and CMS guidance as of this week.

Crisis management in the face of COVID-19. At OHCA, we recognize that emotional hygiene is as critical as handwashing. We will host a free member webinar on April 30, 2020, entitled "Crisis Management in Healthcare." Until then, please see the below resources on emotional well-being for you and your staff. 

  • Mental Health Support for COVID-19 Health Care Workers from John Hopkins University, link to recording and handouts.
  • Enhancing Provider Resilience in the Face of COVID-19 (for home-based providers) from Barry Jacobs Psy. D., handout and recording.
  • How to Lead Through A Crisis, article from the Center for Creative Leadership.