County Positivity Rates for SNF Testing Rule. Yesterday, the Centers for Medicare and Medicaid Services (CMS) released Quality, Safety, and Oversight letter 20-38-NH, which establishes guidelines for periodic testing of SNF staff as mandated by CMS's recent interim final rule with comment period. The guidelines specify that testing fequency is determined by county-level positivity rates. SNFS located in counties with positivity of less than 5% are only required by the rule to test staff monthly, although Ohio's requirement still is bi-weekly testing. The CMS guidelines require SNFs in counties with positivity of at least 5% but less than 10% to test weekly and those in counties with positivity of 10% or more to test twice a week. There is an out to the weekly or semi-weekly testing for centers that do not have point-of-care testing machines or access to laboratory testing with turn-around time of 48 hours or less.

CMS published a link to download a zip file with positivity rates for all counties in the country. Unfortunately, the following Ohio counties are shown as being at or above 10%: Auglaize; Belmont; Darke; Hardin; Holmes; Monroe; Morrow; Pickaway; Preble; Ross; Shelby. Many others are between 5% and 10%. The CMS guidelines indicate the positivity rates will be recalculated each week.

State Releases Upcoming SNF Testing Schedule. The Department of Health today published the following notice on the Enhanced Information Dissemination and Collection (EIDC) system. The notice discusses next week's testing schedule for SNF staff.

Use the following link to access the state-supported nursing home staff testing schedule for specimen collection (swabbing) dates of 8/31-9/6.

https://odh.ohio.gov/static/REGOPS/NH-Staff-Test-Schedule-08-31-To-09-06.xlsx

Important Notes About the Schedule:

1.      Many facilities scheduled to test during the 8/31-9/6 time period will be switching labs.

a.      None of these lab changes affect facilities that have been using Quest.

b.      All lab changes are taking place among labs that use the ODH Lab Form Portal. All facilities with lab changes will continue to use the ODH Lab Portal, and must select their newly assigned lab from the lab down menu.

2.      Facilities using not listed on the schedule for 8/31-9/6 that are using the state-supported process will be on the schedule released for the following week (9/7-9/12)

a.      The schedule for 9/7-9/12 will be released via EIDC by 9/2.

b.      No specimen collections or pick-ups will be scheduled for Labor Day (9/7).

Coronavirus Relief Fund Update. Many OHCA members contacted us over the last number of days with concerns about their applications for funding through the state Coronavirus Relief Fund (CRF). These concerns primarily are that the member did not receive payment for some or all of their provider entities, one or more entities were not on the state's list of providers designated to receive payments, or the member did not receive a response to their inquiries. Today, Office of Budget and Management (OBM) Director Kim Murnieks, Patrick Beatty of the Department of Medicaid, and other staff from the two agencies met with OHCA and other provider associations to give an update on the fund. The following are take-aways from that discussion:

• Director Murnieks reported the state paid $132 million in the first set of payments last week. Another $30 million was paid this week, and another $26 million will be paid next Tuesday or Wednesday.
  
• Mr. Beatty explained that many CRF applications contained provider identifying data that did not match the data in the Medicaid file. Most of the mismatches were names and addresses, particularly zip codes. For each mismatch, agency staff must review the case manually and determine the correct information. The purpose of the extensive matching is to prevent fraud.
• Most mismatches are because the provider entered the facility/agency name and address into the portal instead of the name and address on the Medicaid provider agreement. The Medicaid file has the data from the provider agreement, which may be corporate information.
  
• Mr. Beatty said providers were missing from the master list (mainly SNFs) because wrong names were tied to their provider numbers.
• The agencies are working through the discrepancies and eventually will contact the provider if they cannot resolve them. Any inquiries to CRFprovider@obm.ohio.gov should include the Medicaid provider number(s) of each entity included in the inquiry. Mr. Beatty added that these inquiries take staff away from processing payments.
• The payments to residential care facilities ended up being $500.51 per licensed bed instead of $503.21.
• The second and third payment rounds are being made by electronic funds transfer (EFT) instead of paper checks, as was the case for the first round.
• OHCA argued that matching provider names and addresses is unncessary because the state is using the Medicaid EFT information, which means the payment will go to the actual provider's bank account.

SNFs Receive Latest PRF Payment. Starting early this morning, SNF members notified us that they received large PRF payments. As explained later by letter emailed to providers who received payments, they represented the first part of the $5 billion SNF distribution that the Department of Health and Human Services (HHS) divided into four parts. Today's payment went to all SNFs in the nation, based on a formula, and is intended to help them pay for periodic COVID-19 testing required by the rule and guidelines the Centers for Medicare and Medicaid Services promulgated earlier this week. While recipients are not limited to using the money for that purpose, it is the primary intent for the payment. HHS calculated each provider's amount using a very simple formular: $10,000 plus $1,450 per Medicare-certified bed. The other three parts of the $5 billion SNF tranche will be allocated based on COVID-19 cases at the center, creation of an isolation unit, and participation in Project ECHO.