Health Care Isolation Centers. As mentioned in yesterday's update, the Departments of Health (ODH) and Medicaid (ODM) unveiled a draft process for designating Health Care Isolation Centers (HCICs). HCICs are SNFs or parts of SNFs dedicated to COVID-19-positive or presumptive patients. They may or may not offer ventilator care. They will need to meet ODH specifications and will qualify for enhanced reimbursement for Medicaid patients (although most patients probably will be skilled under Medicare - see article coming tomorrow).
We encourage members who have set up isolation units to apply for designation even though the process is still in draft. OHCA proposed expanding the HCIC concept to include units dedicated to persons under investigation. The state is considering this proposal, but made it clear that they do not intend to pay premium rates for patients who are isolated in place instead of in a special unit. To apply for designation of a HCIC, provide the information requested in Appendix 8 of the state draft plus a floor plan of the unit. Please note that coordination with the regional healthcare coalition is required, so see this link to find your regional contact person ("Find My Healthcare Coalition" tab). Again, remember that this program is in draft and is subject to change.
Workers' Comp dividend. In his press conference today, Governor Mike DeWine announced that to assist Ohio businesses financially, he will ask the Worker's Compensation Board to issue a dividend amounting to $1.6 billion to state-fund employers based on 2018 premiums. The state estimates that the dividend will approximate 100% of premiums for that year. See the written announcement for more information. ID/DD service funding. On a stakeholder call today, Department of Developmental Disabilities (DODD) Director Jeff Davis said that while DODD asked for additional funding for ID/DD providers during the COVID-19 emergency, to date it has not been approved. State tax revenues are down tremendously, and all state agencies were required to submit budget reductions. Director Davis said DODD did so without affecting provider payments, but added that his conversations with providers have not demonstrated that COVID-19 has caused a consistent, quantifiable financial impact. To supply evidence of the increased financial burden they are experiencing, OHCA asks all ID/DD provider members to download and complete a survey from our COVID-19 web page (scroll down to OHCA Materials). Please email the completed survey to Debbie Jenkins.
Separately, DODD issued guidance on situations when waiver disenrollment should take place.
CARES Act grants. Centers for Medicare and Medicaid Services (CMS) Administrator Seema Verma announced that the first tranche of $30 billion of the $100 billion health care fund created by the Coronavirus Aid, Recovery, and Economic Security (CARES) Act will be disbursed to Medicare providers based on their cost report data. The details of the payments are unclear at this time, but we expect them to be made very soon. A second tranche of payments will target providers who do not do significant Medicare business. Again, the details are unclear. Administrator Verma also announced that $34 billion in accelerated advance payments have been made so far.
PPE assistance for OHCA members. OHCA continues to seek reliable sources of personal protective equipment (PPE) for members that don’t require large orders, placed to unknown sources, with money required up front. We are happy to report that Premier and their alternative-site group purchasing organization (GPO) Innovatix (OHCA’s GPO partner for more than 15 years) now have a current, reliable inventory of surgical masks, gowns, and gloves. If you are a member of Innovatix/Premier, contact Bradley Brown at Bradley_Brown@PremierInc.com or 407-902-4302. If you are not a member of Innovatix/Premier, contact Mr. Brown, and he can sign you up within 48 hours.
Nurse aide training waiver. OHCA receives numerous member questions about nurse aide training requirements during the COVID-19 emergency. CMS issued a blanket waiver allowing SNFs to use staff who have not completed nurse aide training and testing to perform services for which they are competent for longer than the 4 months normally permitted. The Ohio legislature, in House Bill (HB) 197, temporarily removed all statutory time limitations, which would include Ohio's version of the 4-month time limit. The fly in the ointment is that ODH has not stated whether they agree that HB 197 extended the time limit, nor have they otherwise implemented the federal waiver. OHCA believes that the 4-month time limit is waived on both the federal and state sides and recommends members use the AHCA 8-hour training course for temporary nurse aides. These individuals will not qualify as state-tested nurse aides in Ohio, but for the duration of the emergency they can perform tasks for which the SNF has found them to be competent.
ODM guidance on Medicaid eligibility determinations and renewals. The Department of Medicaid (ODM) relaxed requirements for eligibility determinations and renewals but did not inform providers or publish the relevant guidance immediately. According to the now-available Medicaid Eligibility Procedure Letter (MEPL) 150, all renewals and redeterminations are suspended through the emergency period. County department of job and family services (counties) are to accept self-attestation of income and resources instead of obtaining verifications, which is usually the delaying factor in long-term care applications. The counties are to process changes only in the limited circumstances identified in the MEPL or when it is positive for the individual. See also ODM's frequently-asked questions document for counties on the emergency eligibility process changes.
On a related point, OHCA is working with ODM on how federal stimulus checks (2020 recovery rebates) that Medicaid beneficiaries receive should be treated for eligibility purposes. ODM verbally indicated that they view this payment as being similar to a tax refund, which would not be counted as income or resources and would not change patient liability or require establishment of a qualified income trust. See also the Congressional Research Service analysis supporting this treatment. We will circulate any formal guidance we receive from ODM on this topic.
Careful with window visits. Window visits are a nice way for patients and residents to connect with family members or friends who are unable to visit in the traditional manner. Just remember - keep the window closed. If it is open, the visitor and the resident will be tempted to get closer than 6 feet from each other, which negates the social distancing value of window visits