Restrictive HHS Terms and Conditions for SNF Distribution; Updated FAQ. The Department of Health and Human Services (HHS) published Terms and Conditions for the latest SNF Provider Relief Fund distribution that came on Thursday. Providers must agree to these Terms and Conditions to retain the payments. Because this latest distribution is targeted at infection control, most notably at covering the cost of mandated staff testing, the Terms and Conditions are more restrictive than for previous distributions. They require the provider to certify that the funding will be used only to cover infection control expenses, defined as costs of testing, reporting the results, hiring staff or contractors to provide patient care or administrative support, other infection control activities such as participating in mentorship programs or physical plant changes, and services and technology for patients to connect with families. For this distribution, the reporting requirements (yet to be released) will include showing a nexus to infection control. In addition, the Terms and Conditions include the following statement: "[t]he Recipient acknowledges that the Secretary may distribute additional payments based on the Recipient’s successful infection control outcomes. The Recipient agrees that it will not take any actions inconsistent with the best interests of its patients in order to increase any such future outcomes-based distribution."

HHS also provided updated frequently-asked questions specific to the infection control distribution.

Corrected SNF Infection Control Distribution Letter. Relative to Thursday's infection control distribution to SNFs, the original letter emailed to providers shortly after they received the payments pointed to an incorrect portal for attesting to receipt and agreeing to the Terms and Conditions. You should have received a corrected letter today. Here is the correct portal.

Trying to Keep the Funding Opportunities Straight? With the various opportunities for COVID-19-related funding that exist and continue to appear, it may be difficult to keep track of them and to determine whether you have taken advantage of everything that is available. With that in mind, we updated our tables for all OHCA member types with the latest information. Tables are available for assisted living, home care, hospice, ID/DD, and SNF providers.

Recording of AHCA SNF Testing Webinar Available. In case you missed it live or would like to refer back to it, AHCA posted a recording of yesterday's webinar on the new Centers for Medicare and Medicaid Services (CMS) SNF testing rule and guidelines. The slides and other materials from the webinar are available at the same link under the handouts tab.

SNF-Hospice Partnership on Testing. The new CMS guidelines mandating testing of SNF staff include contractors such as hospice personnel in the definition of facility staff along with employees. The guidelines and the CMS rule they implement place on the SNF the responsibility for ensuring contracted personnel are tested at the same frequency as employees. We recommend that in the case of hospice personnel, and potentially other contractors that work similarly closely with patients, the most efficient way to meet this requirement is for the SNF to inform the contracting agency of their testing dates and to afford their staff the opportunity to participate. If the hospice staff already were tested elsewhere, the center would need to obtain documentation from the hospice that the testing frequency corresponds with that required of the SNF based on the county's positivity rate. While the guidelines recognize the SNF "may have a provision under its arrangement with a vendor or volunteer that requires them to be tested from another source (e.g., their employer or on their own)," hospices  may not have reliable access to testing to meet the frequency and to provide the SNF with the required documentation.

Open SNF Nurse Aide Training and Testing Sites. Rick Hoover of the Department of Health shared lists of nurse aide training and testing sites that currently are open, if you are looking for options for potential employees to become state-testing nurse aides instead of temporary nurse aides. On both lists, the open sites are highlighted in yellow. Some of the sites may not accept outside applicants.