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December 14, 2020

Assisted Living COVID-19 Test Reporting Cycle Reopens. The Department of Aging reopened its reporting tool for residential care facilities, adult day centers, and senior centers today. It is open through Wednesday, December 16 and applies to results from the biweekly testing period of November 23-December 6, 2020. All of the information required must be completed in one session, and only one report should be submitted for each reporting period. Successful submission generates the message: "Thank you for taking the survey." Any questions should be directed to

Assisted Living: PRF Phase 2 General Distribution. Scott Tittle of NCAL reported that some assisted living members still have not received payments for which they applied under Phase 2 of the Department of Health and Human Services (HHS) Provider Relief Fund (PRF) General Distribution. Others received notices that their Tax Identification Numbers were deemed to be ineligible. If either of these things happened to you, please let OHCA know. Note that this is Phase 2, not the Phase 3 General Distribution payment, which no one has received yet.

We understand that some DD service providers also may be in this situation. If that is the case for you, please contact Debbie Jenkins, and she will communicate with ANCOR.

CMS Enforcement Discretion for Antigen Testing. ODH's James Hodge provided us with a link to a upcoming Centers for Medicare and Medicaid Services (CMS) question-and-answer notice clarifying that a facility that files an application for a Clinical Laboratory Improvement Amendments Certificate of Waiver may begin conducting tests before receiving the certificate. To apply for a Certificate of Waiver, complete the sections of the CMS-116 form applicable to a Certificate of Waiver, attach a W9 form, and email it to  

COVID-19 Vaccine Notes. At a press conference today, Governor Mike DeWine made an announcement about an early SNF vaccination pilot. According to the release following the press conference:

The Centers for Disease Control and Prevention has invited Ohio to participate in an early scaled launch of vaccinations in nursing homes. Ohio will begin providing vaccinations in five to ten nursing homes starting this Friday, December 18. Ohio had previously been scheduled to start its nursing home vaccination program in partnership with pharmacy providers on Monday, December 21.

We are not aware of which facilities are included in this pilot.

In a meeting today, AHCA's Dr. David Gifford added to his previous statement that Walgreens and CVS would accept emailed consents to include documented verbal consent. He later followed up in writing:

They are working on updating their FAQs but we can confirm 100% that CVS and Walgreens will accept verbal, email, or other forms of consent but you will need to document in the medical record as you normally would for informed consent and likely will need to complete the CVS or Walgreens form saying you got consent, from who and how.

We received a number of messages from members today indicating that they had not heard from their pharmacy partner, per our suggestion in last night's COVID-19 Update. We are sharing these providers with AHCA/NCAL to check against their list of Pharmacy Partnership for Long-Term Care participants. Two tips that may be helpful:

  • First, check spam, junk, or quarantine filters for the email address of the person listed as the contact person when you registered for the partnership.
  • Second, if CVS is your chosen pharmacy partner, make sure to verify your primary and secondary contact information with them.

The Department of Health (ODH) circulated this week's edition of the Ohio Vaccine Preparedness Office Weekly Update. The newsletter has a number of resource links as well as tips for talking about the vaccine.

Reminder: AHCA/NCAL Vaccine Office Hours. AHCA/NCAL is holding two office hours sessions this week that will be devoted entirely to questions and answers about the COVID-19 vaccine. These sessions are scheduled for tomorrow, December 15, at 11:00 a.m. and Wednesday, December 16, at 4:00 p.m. You may register for either or both at this link.

COVID-19 Vaccine Codes: Updated Effective Date for Pfizer-BioNTech. The following material appeared in the Centers for Medicare and Medicaid Services Medicare Learning Network (MLN) Matters. The article relates to billing for vaccine administration, which is not directly relevant to providers participating in the Pharmacy Partnership for Long-Term Care but may be relevant for providers who end up administering vaccines themselves at some time in the future. Please note that only providers who directly administer the vaccine may bill for it.

On December 11, 2020, the U.S. Food and Drug Administration issued an Emergency Use Authorization (EUA) for the Pfizer-BioNTech COVID-19 Vaccine for the prevention of COVID-19 for individuals 16 years of age and older. Review Pfizer’s Fact Sheet for Healthcare Providers Administering Vaccine (Vaccination Providers) regarding the limitations of authorized use.

During the COVID-19 Public Health Emergency (PHE), Medicare will cover and pay for the administration of the vaccine (when furnished consistent with the EUA). Review our updated payment and HCPCS Level I CPT code structure for specific COVID-19 vaccine information. Only bill for the vaccine administration codes when you submit claims to Medicare; don’t include the vaccine product codes when vaccines are free.

BID Doubles Down on Five Donnings. We recently reported that Amanda Smith of ODH's Bureau of Infectious Disease (BID) told us that according to Centers for Disease Control and Prevention guidance, N95s need to be discarded after five donnings and doffings. This caused a (rightful) outcry among members about the impracticality and wastefulness of this guidance. OHCA pushed back with the ODH Survey Bureau, asking whether they would cite deficiencies under these circumstances, and received the answer, "[i]t is something we would investigate and may result in a citation." We also pushed back with BID and, unfortunately, received the following written statement from Ms. Smith:

Thank you for contacting the Ohio Department of Health regarding personal protective equipment (PPE) concerns. The guidance provided by the Centers for Disease Control and Prevention (CDC) is based on research conducted by the National Institute for Occupational Safety and Health (NIOSH) that showed the more respirators were donned and doffed, the greater the chance that the respirator would not maintain a proper seal due to stretched out straps or loss of shape in the respirator. They found in this research that, on average, this happened after the fifth donning. If respirators do not have the proper seal, then the staff would not be adequately protected. We understand that these are difficult times for everyone and the safety of our healthcare personnel are of the utmost importance so they can continue the important work that they do keeping residents safe. This guidance is recommended for all healthcare settings including residential care facilities (RCFs), hospitals, and long-term care facilities (LTCFs) that are re-using respirators. Facilities should continue to evaluate their supply inventory daily to anticipate their needs. If individual facilities are in contingency or crisis status for their PPE, we urge them to reach out to their local health department and local emergency management agency if they cannot obtain supplies through their normal channels. As part of the guidance on reuse, CDC also advises in crisis situations that if there is a need to reuse respirators more than the five donnings, the occupational health coordinator should consider implementing a qualitative respirator fit performance evaluation.

CDC Strategies for Optimizing the Supply of N95 Respirators, Updated November 23, 2020

“It is important to consult with the respirator manufacturer regarding the maximum number of donnings or uses they recommend for the N95 respirator model. If no manufacturer guidance is available, data suggest limiting the number of reuses to no more than five uses (five donnings) per device by the same HCP to ensure an adequate respirator performance. HCP should always inspect the respirator and perform a seal check upon donning a re-used respirator. For N95 respirators that have been donned more than five times and may need to be re-used again, respiratory protection program managers should consider implementing a qualitative respirator fit performance evaluation. N95 and other disposable respirators should not be shared by multiple HCP.

During times of crisis, practicing limited re-use while also implementing extended use can be considered. If limited re-use is practiced on top of extended use, caution should be used to minimize self-contamination and degradation of the respirator. If no manufacturer guidance is available, a reasonable limitation should continue to be five total donnings regardless of the number of hours the respirator is worn.”

HHS Addresses Vaccine Administration Costs in PRF FAQ. HHS posted changes to its frequently-asked questions (FAQ) document on the PRF. Search "12/11" in the document for the most recent revisions. Among these changes are two (see page 27) clarifying that PRF payments can be used to cover the costs of COVID-19 vaccine administration, to the extent those costs are not reimbursed by other sources. Other changes affirm that providers can use PRF funds to pay taxes (except for SNF Infection Control payments), expenses for securing and maintaining adequate personnel, and outsourced or vendor services.