Skilling for COVID-19, spell of illness, and coding. Taking a closer look at AHCA's guidance on skilling patients affected by COVID-19, one can conclude that the temporary 3-day stay waiver allows most if not of them to qualify for Medicare Part A coverage whether they come from a hospital or the community or are already in the SNF. Either the patient will qualify based on other skilled services they receive or, following the Centers for Disease Control and Prevention (CDC) recommendations for close monitoring of COVID-19 patients and persons under investigation, they will qualify based on nursing observation. This applies even to patients isolated after being admitted from a hospital (they likely will have other skilled needs) or after being exposed to a confirmed positive person in the SNF (nursing observation).
The same AHCA guidance document contains a frequently-asked questions (FAQ) section that gives the association's interpretation of the Centers for Medicare and Medicaid Services' (CMS's) waiver of the spell of illness requirement. Although CMS has not provided definitive direction on the question, AHCA suggests that the waiver does not allow extension of the 100-day skilled care limit unless there is a change in the skilled services the patient requires (see questions 9 and 10 of the FAQ).
The FAQ also provides detail on claim and MDS coding for COVID-19 (see pages 7-8).
SNF cost and revenue loss survey. Any SNF member reading this undoubtedly saw the multiple messages today about the Department of Medicaid (ODM) cost and revenue loss survey, so we simply ask that if at all possible, you complete the survey or send a spreadsheet with the data requested on the survey to Elizabeth.Effah@medicaid.ohio.gov by 5:00 p.m. tomorrow (Friday). We understand the survey is an enormous pain when the last thing anyone needs is more work, but it is important to demonstrate the economic impact of COVID-19 on providers to justify emergency Medicaid fundingas OHCA requested. We would apprecaite if you also could send a copy of your data to pvanrunkle@ohca.org. Hold HCIC applications. Yesterday, we suggested that members interested in becoming designated as Health Care Isolation Centers (HCICs) apply to the Department of Health (ODH) with the information listed in Appendix 8 of the state's draft HCIC guidelines, together with a floor plan. Today, ODH asked all applicants to wait until the department completes an actual application form, which they said should be available tomorrow.
State Pre-Surge Planning Toolkit for LTSS Providers. Endorsed by ODH, ODM, the Department of Developmental Disabilities (DODD), and the Department of Aging, this 26-page document lays out the state's guidance for care and transitions of care in the community and in facilities. Along with multiple charts showing patient and staff journeys depending on 3 levels of patient conditions and 3 levels of personal protective equipment (PPE), the packet includes various tools for assessments, symptom monitoring, and other uses that are linked to the charts.
CDC/CHAP home care guidance. For patients discharged directly to home with COVID-19, CDC developed guidance on discontinuing home isolation for immunocompromised persons with COVID-10 when a test-based strategy is feasible. This complements their guidance on discontinuating isolation for persons with COVID-19 not in healthcare settings. Additionally, Community Health Accreditation Partner (CHAP) recently released a caregiver instruction fact sheet for persons caring for COVID-19 positive patients in their homes. This guidance applies to home health, home care waiver providers, and home-based hospice care.
Updated DODD Residential Crisis Plan. This article is revised from Tuesday's COVID-19 Update and has updated links. The Department of Developmental Disabilities (DODD) finalized its Regional Residential Crisis Support Plan and a Cross-Functional Flowchart for Residential Resource Crisis Response and Coordination. The goal is to assist providers experiencing a residential crisis through regional teams that will supplement and support local teams already in place. Providers experiencing a residential crisis who exhaust their internal resources should contact their local county board representative. If the local team needs additional support, they should contact the DODD Statewide Support Liaison in their region. If any changes need to be made to the regional map or you have questions about the plan, please contact Sara Lawson, 614-420-4058, sara.lawson@dodd.ohio.gov.
Other DODD items. DODD published guidance explaining temporary changes to adult day services and offered a webinar entitled, "Adult Day Supports and COVID-19: Response, Guidance and Practice" on April 17 at 1:00 p.m.
Molina issues relief for providers. Molina Healthcare released a bulletin last night outlining several changes during to the COVID-19 emergency period for providers:
- Existing authorizations are extended to September 30, 2020, for managed Medicaid plans and August 31, 2020, for managed Medicare and Marketplace plans.
- The following changes to prior authorization requirements for new admissions and starts of care were made:
- Managed Medicaid: Home health authorization not required for first two weeks of care. Private Duty nursing still requires precertification. SNF stays do not require prior authorization, but level of care is still required. Please submit a face sheet indicating admission and expected discharge date.
- Managed Medicare and Marketplace: there are no changes to prior authorization requirements. All new starts of care and admissions require precertification.
- Timely filing limits for managed Medicaid claims submitted after March 27, 2020, are extended to 365 days. There is no change for managed Medicare and marketplace plans.
- The 2% sequestration deduction for managed Medicare payments is suspended effective May 1, 2020, through December 31, 2020.
- Acceptance and full application of all telehealth expansion approvals from CMS and ODM.
For a full list of changes, please refer to the network bulletin.
OSHA respiratory protection memos. Adding to the list of problems caused by the shortage of personal protective equipment (PPE) is the possibility of penalties from the Occupational Safety and Health Administration (OSHA). OSHA published two memos that to some degree recognize the challenges at hand. The first memo discusses extended use, re-use, and past-date use of N95 respirators. The second memo allows similar respirators certified under other countries' standards. Unfortunately these memos do not appear to go as far as CDC guidance.
Toward Independence appreciates its DSPs. DODD recognized OHCA member Toward Independence with the following article.
Toward Independence is a residential provider that has been providing support and services to the developmental disabilities community for over 40 years. With more than 400 dedicated employees, Toward Independence serves 190 residents in 61 small integrated homes in communities across Ohio.
Mark Schlater, CEO of Toward Independence, is on a mission to make sure his staff knows they matter, especially during this unprecedented time. “I am very passionate about recognizing the efforts of our direct support professionals (DSPs),” shares Schlater, who also served as a leader of the 2019 Bridge2Equality Statehouse rally and campaign focused on raising awareness about the DSP workforce. “They are working hard on the front lines each day and truly care about our people.” Because DSPs provide people with developmental disabilities the service and support they need to live their lives, Schlater feels that being a DSP is a hidden vocation. “When people see hospitals, nursing homes, assisted living communities, they see buildings. They don’t see the support.”
To bring awareness to how vital the DSP role is, Toward Independence recently produced a tribute video, which has garnered tens of thousands of views. In addition to sending positive messages to remind DSPs of the importance of their work, Toward Independence has been delivering food to homes for staff and finding other ways to continue showing their appreciation. Learn more about Toward Independence.