Elevating the Post-Acute and
Long Term Care Profession

April 1, 2020


PPE plane arrives. Last night, ODH sent out a news release reporting that the shipment of personal protective equipment (PPE) President Donald Trump said was coming to Ohio had arrived. The news release lists quantities of different PPE items included in the shipment and states, "[a]ll shipments have been received by ODH and all will be sent to county locations to ensure local PPE needs are met." If you are out of PPE, we strongly recommend you immediately contact your county emergency management agency (EMA) and get in line for the county's portion of the shipment when it arrives. Please use this link to locate your county EMA.

Licensing nurses without exam. The Board of Nursing released a memo explaining that House Bill 197 allows nursing students who had completed their coursework or were in their last semester when the COVID-19 emergency began can be licensed without taking the nursing examination. The board estimates there are 4-5,000 nursing students in this position. Please review the memo for more on the licensing process.

CMS MDS waiver. According to the COVID-19 Healthcare Providers Fact Sheet, the Centers for Medicare and Medicaid Services (CMS) "is waiving 42 CFR 483.20 to provide relief to SNFs on the timeframe requirements for Minimum Data Set assessments and transmission." This wording could be read to suggest that during the COVID-19 emergency, SNFs no longer are required to complete MDSs. That would be a mistake. A MDS still must be completed to bill Medicare under the Patient-Driven Payment Model (PDPM) because claims must include Health Insurance Prospective Payment System codes generated from MDS assessments. Moreover, the Medicare Policy Benefit Manual requires that for Medicare to render payment for Part A skilled services, the SNF must complete a MDS. Medicare guidance on the emergency waivers, however, specifies that a SNF may submit the MDS outside of the 14-day window and use condition code DR on the claim to bypass the normal edits.  

COVID-19 ICD-10 code for PDPM. CMS provided an updated mapping file listing a new International Classification of Diseases, Tenth Revision, Clinical Modification (ICD-10-CM) code for COVID-19: U07.1 - 2019-nCoV acute respiratory disease. This code can be used as the primary reason for the SNF stay. It applies to the PDPM therapy components, but not to nursing or non-therapy ancillaries, and only can be used on assessments with target dates April 1, 2020, and after. Please make sure your software vendor updates their software to include this code before attempting to use it.

DODD guidance on intial medication administration training. The Department of Developmental Disabilities (DODD) issued a memo allowing remote delivery of part of the initial training on medication administration for unlicensed personnel. The requirements for doing this, as described in the memo, actually are rather restrictive.

ODH background check letter. This afternoon, the Health Department posted a letter by James Hodge on criminal background checks. Mr. Hodge wrote that while the department had heard anecdotally that some fingerprinting locations were closed, job applicants could go elsewhere to get fingerprinted. OHCA feels this letter was incomplete because Mr. Hodge did not point out that House Bill 197 temporarily eliminated the statutory time limitations for submitting fingerprints and for employing an individual who has not been background-checked.


With Support from OHCA Champion Partners