Apply for Paycheck Protection Program. We recommend that all members who qualify apply for Paycheck Protection Program (PPP) loans as a way of injecting much-needed cash into their operations. The program is part of the Coronavirus Aid, Response, and Economic Security (CARES) Act. The loans are 100% guaranteed by the Small Business Administration (SBA) and carry only 0.5% interest, but the best part is they can be forgiven if at least 75% of the money is used for payroll expenses during the following 8 weeks. In essence, it becomes a grant. The maximum loan amount is the lesser of $10 million or 2.5 times average monthly payroll. This is a small business program, defined as fewer than 500 employees, and the numbers for related businesses are aggregated. Please see this memo from AHCA legal counsel Reed Smith on employer eligibility and this online post for more information on PPP generally. The SBA posted a sample application form that small businesses can use, and the SBA web page on PPP is here.

Health recommends universal masking. Yesterday the Health Department (ODH) released a spate of materials relating to personal protective equipment (PPE). The most notable item was a revised version of their document on PPE optimization that includes the statement, "ODH is recommending that all staff in long-term care facilities wear a surgical/medical facemask while working to avoid asymptomatic transmission of COVID-19 to residents and other staff. This includes facilities not known to be affected by COVID-19." The next paragraph of the guidelines discuss use of homemade masks as a "last resort" when facemasks are not available. Other PPE-related materials from ODH include:

• Instructions for re-using facemasks.
• A PPE contingency planning chart. While the chart attempts to simplify the Centers for Disease Control and Prevention (CDC) recommendations, it is missing a couple key strategies in the CDC material. We recommend consulting the OHCA PPE optimization guidance, taken directly from CDC, in this online folder.
  
• A list of instructions and videos on PPE use.
• Guidance on using N95 respirators.

Medicare fee-for-service medical reviews suspended. CMS issued a notice that they suspended most medical reviews for the duration of the emergency period. Current reviews will be released. This policy applies to all types of pre-payment and post-payment reviews, including that favorite of Ohio home health agencies, the Review Choice Demonstration, except in cases of potential fraud. Please see the notice for details. The suspension only applies to fee-for-service Medicare, although CMS suggested previously that Medicare Advantage plans do the same.

ODH COVID-19 testing guidelines. ODH released an updated version of their guidelines for testing, which are based on CDC and show symptomatic people in long-term care in the second priority tier. Symptomatic health care workers are in the first tier, although it is not clear who is considered a health care worker for this purpose. The document also describes testing procedures.