CRF Issues? A number of members have communicated issues with the state's Coronavirus Relief Fund payments over the last several days. These issues range from providers not included on the state's master list to providers on the list not receiving emails on Tuesday to providers listed with incorrect identifying information and more. According to the Office of Budget and Management (OBM), most of these problems derive from the data OBM received from the Department of Medicaid (ODM), so they encourage providers to contact ODM. As some questions still might be within OBM's purview, we recommend contacting both CRFprovider@obm.ohio.gov and Medicaid Deputy Director Patrick Beatty at Patrick.Beatty@medicaid.ohio.gov. If you need further assistance, please feel free to involve OHCA.

ODH Answers Questions. We had a second meeting yesterday with the Departments of Health (ODH) and Medicaid during which the agencies answered some additional questions.

• Even spouses who share a room or apartment in a SNF or assisted living community must socially distance in the dining room.
• Positive COVID-19 test results from the antigen point-of-care (POC) units the Department of Health and Human Services (HHS) is distributing to SNFs must be reported and will be posted on the ODH dashboard in the same manner as positive molecular tests.
• SNFs will not be assigned to test staff on Labor Day. This will be clarified when the next testing schedule is released.
• Jay Rogers of ODH asked us to remind SNF members that the National Guard has between 8:00 a.m. and 5:00 p.m. to pick up specimens, and they are supposed to call the facility en route. Mr. Rogers said he receives calls starting about 8:15 a.m. asking the whereabouts of the Guard.
• ODH's Jill Shonk said the department took down the MDS 3.0 webinar discussed in last Saturday's COVID-19 Update. We reported the two incorrect statements on the webinar to ODH.
• Julie Evers of ODM directed SNFs to question 9 on the testing frequently-asked questions document for information on billing for state-mandated COVID-19 testing. Question 9, however, does not address specifically what happens when an insurance company denies a claim because the staff person tested did not have symptoms.
  
• Ms. Shonk reported that the Centers for Medicare and Medicaid Services Central Office has a workgroup looking at changes to the survey process to take account of COVID-19. Restarting surveys for all federally regulated provder types, including ICFs/IID and non-long-term care, is tied up in this.
• Mr. Rogers reminded us that a Director of Health rule waiver allows training programs for nurse aides in SNFs to deliver all of the classroom content virtually until 60 days after Governor Mike DeWine lifts the state emergency declaration. OHCA suggested that ODH adopt this waiver permanently. This waiver is different from the federal waiver that allows a SNF to employ a person as a nurse aide for more than 4 months without enrolling in or completing an approved training course and testing, if they are competent to perform their tasks.
  
• Facilities can use an exterior door alarm system that displays a photo of a resident who triggered the alarm if they obtain consent and consider residents' rights. This system works with bracelets worn by residents with cognitive impairment who are assessed as presenting elopement risk. State Ombudsman Bev Laubert warned that the bracelets should not be assigned to other residents for staff convenience.
• Mr. Rogers offered a further reminder, this time about the Bridge Team process created to assist SNFs (and potentially assisted living communities) with a staffing crisis resulting from positive COVID-19 test results. Providers should not wait until the last minute and then request the National Guard to come in to address the crisis. The first two levels are locating staffing agencies that the provider might not have contacted and sending a message to the licensee list that ODH maintains. Mr. Rogers added that they usually get 5-6 responses from the licensee list within 6 hours of contacting them.

CLIA Laboratory Reporting Requirements Related to COVID-19. Recognizing that increasing numbers of SNF members will receive antigen POC testing units in the days to come, we wanted to inform members of the reporting requirements that will apply when they begin to use the machines.

A SNF with a Comprehensive Laboratory Improvement Amendments (CLIA) Certificate of Waiver is required to follow the same COVID-19 reporting requirements as any CLIA laboratory when administering COVID-19 tests. Once you receive your POC unit, you should perform the following steps to comply with the COVID-19 laboratory reporting requirements.   

Register Your Lab for Daily Aggregate Reporting of COVID-19 Tests Performed

On May 13, 2020, the Director of Health issued an order mandating that any laboratory performing COVID-19 testing on Ohio residents must submit daily, 7 days a week, by 11:00 a.m., aggregate daily totals of all testing performed. This mandate includes all types of COVID-19 tests (polymerase chain reaction (PCR)/molecular, antigen, serology, etc.). To comply with  this requirement, you first must register your lab. Once approved, you will be required to complete the State of Ohio COVID-19 Laboratory Testing Report. Fortunately this is a relatively simple report. Unfortunately, you must submit the report daily even if you perform no COVID-19 tests on a particular day. In those cases, you simply would report zero in all the required fields.

Line-Level Reporting of All Positives Cases

Positive results for all types of COVID-19 tests performed on Ohio residents must be reported to the local health department where the person resides within 24 hours of case identification. Over the next few weeks, OHCA believes the easiest way to report positive cases is to complete the Ohio Confidential Reportable Disease Case Report Form and to fax it to the local health department in the county where the staff member resides. The ODH Find My Local Health Department Portal is a great tool for confirming the health district for any address in Ohio. With respect to the Case Report Form, simply list COVID-19 as the disease reported and do not worry about the Ohio Disease Reporting System (ODRS) number, which is an auto-generated number for labs that choose to submit line-level case reports directly into ODRS. ODH asks that you include in the remarks field what type of COVID-19 POC test was performed. At this time, it is either the Sofia SARS Antigen FIA manufactured by Quidel (aka Quidel Sofia) or the Veritor System for Rapid Detection of SARS-CoV-2 manufactured by Becton, Dickinson (aka BD Veritor), whichever unit you received.

Take Steps Now to Move to Reporting Via a Secure File Upload

Currently in Ohio, labs only are required to submit line-level reports on positive COVID-19 cases. Within the next few weeks, however, all labs will be required to report line-level data on all COVID-19 tests, including tests with negative results. ODH has been working for months to build a system to accept this line-level data so COVID-19 positivity ratings and other health indicators can be drilled down to the county level. OHCA believes the easiest way for SNFs to comply with this forthcoming line-level data reporting requirement is to create a secure data interchange with ODH. This will allow you to pre-populate all your staff demographic information into a central CSV file and only upload, on a daily basis, data for those tests run that day.

We encourage you to begin this process now. To do so, you first must sign up for the secure file transfer process by completing the ODH SFTP Request Form. Once you achieve connectivity with ODH, you will begin testing data transfers. This CSV schema formatting file provides the information and mapping details that supports the 50+ data fields HHS and ODH require for COVID-19 laboratory reporting. Again, while reporting line-level negative cases is still a few weeks away, we encourage members to begin this process now. OHCA will continue to explore with the two POC manufacturers whether their units have any data interface capabilities for lab reporting. Nonetheless, ODH indicated that a secure file upload connection still will need to be in place between the lab (SNF) and ODH and the data pulled from each POC unit will need to include the required fields in the CSV schema formatting file.

In summary, as soon as members begin to use their POC units to conduct testing, they must register their labs and begin reporting aggregate daily testing totals to ODH. In addition, any positive cases are to be reported to the local health department where the staff member resides. Finally, we suggest you begin the process now to set up a secure data interface with ODH. This will allow you not only to report positive cases but also to comply with the requirement to report all cases, including negatives, to ODH in the weeks ahead.