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December 7, 2020

COVID-19 Vaccine Update; AHCA/NCAL and ODH Information. OHCA learned from ODH on Saturday that the previous afternoon, the Centers for Disease Control and Prevention (CDC) locked the initial list of long-term care facilities for the Pharmacy Partnership for Long-Term Care. We hope to receive a copy of the list in the next day or two so we can verify for members whether they are included. It is our understanding that this list includes at least SNFs, assisted living communities, and ICFs/IID.

Four pharmacies are participating in the Partnership: CVS and Walgreens, which will serve the vast majority of facilities, and also Absolute and Pharmscripts. The latest prediction for the start date of vaccine clinics at participating facilities is December 21, since Ohio is using the BioNTech/Pfizer vaccine.

Today, CVS held a national webinar to discuss its process for scheduling and conducting the clinics. The slides from the webinar are available on CVS's vaccine distribution web page, along with a variety of other information, including a sample of their consent form. The clinic dates are non-negotiable. CVS strongly urged providers who are partnering with them to update their contact information.

Walgreens previously posted a pre-recorded video about the Partnership and their sample consent form. They also produced a facility tip sheet.

AHCA/NCAL is offering a webinar entitled, "Preparing for COVID-19 Vaccine Clinics," at 4:00 p.m. on Thursday, December 10. You may register for the webinar at this link.

Today, the Health Department (ODH) distributed via the Enhanced Information Dissemination and Collection System (EIDC) a vaccination update dated last Friday. This document contains information about the state's vaccination program as well as talking points for providers to use to educate about vaccination. ODH also published a frequently-asked questions document targeted more to consumers. ODH directs questions to

HHS Announces Lastest SNF QIP Payment. The Department of Health and Human Services (HHS) today announced that it is making SNF Quality Incentive Program (QIP) payments for October starting Wednesday, December 9. Instead of separate amounts, as for September, HHS will combine the case-based and mortality-based sums. The larger October outlay of $523 million will go to 9,248 SNFs, fewer than in September. According to HHS's state-level table, 594 Ohio SNFs will share $27.5 million.

DODD Shares Updated Provider Contacts. The Department of Developmental Disabilities (DODD) shared an updated county board (CB) COVID-19 contact list. The department also asked providers to indicate any emergent needs on email or voicemails left for the CB contact. DODD asked CBs to prioritize responding to emergent requests. If you are having issues getting a response from your CB, please email Debbie Jenkins.

Monoclonal Antibody Treatment Education for HHAs. The Assistant Secretary for Preparedness and Response is sponsoring an educational mini-series on COVID-19 therapies for which the Food and Drug Administration recently granted Emergency Use Authorizations, including monoclonal antibodies. These therapies are intended to be administered in outpatient settings, including patients' homes, to people with mild to moderate COVID-19 symptoms. Home health agencies (HHAs) are eligible to administer and to bill for these treatments, including in non-traditional settings such as SNFs. The treatments are not included in SNF consolidated billing, so there are financial incentives for both post-acute provider types. While the treatments are not yet widely available, HHA providers can begin to familiarize themselves with the use and operationalization of the treatments with these educational sessions. The first two sessions are scheduled for December 9 and December 16 at 12:00 noon. Click here to register.

CMS to Restart SNF Five-Star. CMS released Quality, Safety, and Oversight letter (QSO) 21-06-NH, which spells out how the agency intends quickly to unfreeze the Five-Star Quality Rating System for SNFs, which was frozen in the spring. CMS previously resumed calculating staffing stars, so the new QSO affects the survey stars and the Quality Measures. Both of these components will be refreshed January 27, 2021. For the survey stars, Focused Infection Control surveys will be treated like complaint visits. For the Quality Measures, CMS plans to issue a new version of the Technical Users' Guide on January 15. CMS also announced in the QSO that their new, combined compare site, Care Compare, now is the only option for health care provider data searches, as the individual compare sites were retired December 1.

CMS Hosting Special Office Hours December 9 on Hospitals Without Walls. On November 25, CMS announced that they are expanding the Hospitals Without Walls program through an innovative Acute Hospital Care at Home program. This program gives eligible hospitals unprecedented regulatory flexibilities to treat eligible patients in their homes. Many people have speculated that this expansion will further drive referrals into home health care. The CMS stakeholder call, scheduled for December 9 at 4:00 p.m., will feature two leading organizations walking through their programs as well as a question and answer session. HHAs can learn more about the operation of the program and how to find out which hospitals are participating.

Toll-free attendee dial-in: 833-614-0820; access passcode: 1235939.

Audio webcast link:

Latest CMS Positivity Data. CMS released this week's county-level COVID-19 testing positivity data for SNF testing and visitation. This week's table has 20 yellow counties, with the rest being red. This week actually is a slight improvement from last week, when 71 counties were red and 17 yellow.

No CRF Reporting Requirements. A number of members have asked whether there are or will be any reporting requirements for Ohio's Coronavirus Relief Fund (CRF) payments to providers, as there are for the HHS Provider Relief Fund. Our best information previously was that there would be no such requirements, and the Office of Budget and Management confirmed as much this evening in a message to CRF recipients:

You are receiving this email because you were listed as the grant contact or authorized representative on your organization’s application for Provider Relief Funds distributed from the State of Ohio using federal Coronavirus Relief Funds. OBM has received several questions recently regarding the use of funds, timelines, and reporting of funds. Attached is the Provider Guidance for your reference. Here are some additional points we would like to point out as the funds are set to expire on December 30, 2020:

  • These funds were provided as economic relief payments to providers to compensate for increased costs related to the pandemic, as well as revenue losses. A provider may document COVID related revenue losses and utilize the funds for an amount up to the total losses determined (less any other revenue loss funds provided from other funding sources such as HHS or PPP programs) against reoccurring business costs that would have been covered by the lost revenue. Examples of these types of business interruption costs include rent, utilities, personnel that was continuously funded, etc. It is important to note that a 1099 will be issued to you for these funds as you may have used the funding for revenue losses. Please discuss any tax implications of funding with your tax professional. Be aware that you may be contacted in the coming weeks if it is found that an incomplete or inaccurate tax identification number was provided during the application process.
  • If a provider determines they have remaining funds that they cannot apply to revenue losses or increased costs to respond to the pandemic, please contact before returning any funds. This will allow OBM to analyze the specific circumstances to determine IF any funds are indeed required to be returned and to coordinate the return.
  • It has come to our attention there is some confusion on the timeline on use of these funds in relation to other sources such as HHS Provider Relief Funds. These funds were provided from the state’s allocation of the Coronavirus Relief Fund and costs must be incurred by December 30, 2020. When strategizing use of funds, providers are encouraged to use these funds for costs first prior to utilizing HHS Provider Relief Funds since those have to be expended no later than June 30, 2021.
  • As noted in the Provider Relief guidance document issued at the time of the funding opportunity (see attached), providers would be notified if additional reporting is required. Since payments are considered direct beneficiary payments for economic relief, there are no additional reporting requirements at this time. Should guidance from the U.S. Treasury change, OBM will provide additional notifications and guidance. Please continue to maintain records as required for a period of five years. In addition as noted in the original guidance, regular cost reporting rules continue to apply.

 As always, please let us know if you have any additional questions.

ODH Quarantine Guidance. The Department of Health (ODH) issued guidance last Friday that incorporated and restated last Wednesday's new CDC guidelines that recognize that science supports shorter quarantine periods than the previous 14 days. The ODH guidance, however, states relative to long-term services and supports, "[a] 14-day quarantine period presents the lowest risk of post-quarantine transmission. This strategy is preferred for people living in, working at, or visiting congregate living facilities, high density workplaces, or other settings where potential extensive transmission or contact with people at increased risk for severe illness from COVID-19 is possible." While ODH prefers a 14-day quarantine period, considerations such as staffing shortages and need to free beds for admissions from hospitals would seem to be overriding considerations. OHCA inquired of ODH whether surveyors will seek to enforce the stated preference as if it was an actual rule.

Becerra Tapped for HHS Secretary. President-Elect Joe Biden selected Xavier Beccera as his nominee to head HHS. Mr. Becerra, a former Member of Congress from California and part of House of Representatives leadership, currently is serving as California Attorney General. The HHS position is subject to Senate confirmation.

More NHSN Training Sessions Available. In case you missed the National Healthcare Safety Network's (NHSN's) webinar on changes to its reporting process for aggregate SNF COVID-19 testing data, they are offering additional opportunities. Please see NHSN's COVID-19 module web page and scroll down to "Upcoming Webinars." The changes, which took effect November 23, add complexity to the reporting of test results, so if you haven't seen the webinar, it is worthwhile.