Clarification of Phase 1B. In his comments today and in the subsequent press release, Governor Mike DeWine clarified that people with intellectual or developmental disabilities living in the community are included in Phase 1B of the state's COVID-19 vaccination plan only if they also have certain specified medical disorders. People meeting both of those criteria will be included in the group eligible for vaccinations next week, along with people 75 and older. Individuals with one of the specified medical conditions but not ID/DD are scheduled for vaccination the week of February 15, after people 70 and older (week of February 1) and 65 and older (week of February 8). The medical conditions are:

• Cerebral palsy
• Spina bifida
• Severe congenital heart disease requiring hospitalization within the past year
• Severe type 1 diabetes requiring hospitalization in the past year
• Inherited metabolic disorders, including phenyketonuria
• Severe neurological disorders, including epilepsy, hydrocephaly, and microcephaly
• Severe genetic disorders, including Down syndrome, frgile X syndrome, Prader-Willi syndrome, Turner syndrome, and muscular dystrophy
• Severe lung disease, including asthma requiring hospitalization within the past year and cystic fibrosis
• Sickle cell anemia
• Alpha and beta thalassemia
• Solid organ transplants.
  

According to the release, "[a] representative from the local county developmental disabilities board will reach out to help coordinate receipt of the vaccination for Ohioans with severe congenital, developmental, or early-onset medical disorders, as well as a developmental or intellectual disability." People with ID/DD living in congregate settings already were included in Phase 1A.

Please Complete Temporary Nurse Aide Survey. One of OHCA's near-term legislative agenda items is assisting temporary nurse aides (TNAs) when the current Public Health Emergency (PHE) ends. The PHE supports the federal waiver allowing TNAs to work in SNFs without completing the 75-hour nurse aide training program and the state-administered test required by federal regulations and state law. Our proposed legislation would give TNAs credit toward the required hours of training for training they received as part of their employment, enabling them to qualify as state-tested nurse aides. To support this proposal, we need to know how many TNAs are working in Ohio SNFs. Without the legislation, these experience workers would lose their jobs or be required to take time off to participate in an essentially redundant training program when the PHE ends. We ask all SNF members to complete this brief Survey Monkey by Monday, January 25. Please fill it out whether or not you use TNAs. The survey is only for SNFs, as other providers are not covered by the nurse aide training/testing requirements. 

CMS Positivity Ratings for SNF Testing Steady. This week's Centers for Medicare and Medicaid Services (CMS) COVID-19 test positivity rates for Ohio are essentially unchanged from last week. Fairfield County moved from red to yellow and Highland and Logan Counties from yellow to red. All other counties remained the same. This stagnation is because most of the yellow counties are yellow because they did not perfform enough tests, not because they have low positivity. Only certain counties have small enough populations that they are likely to have insufficient numbers of tests, so there is little movement between the two groups. Under the CMS testing requirements, SNFs in yellow counties are mandated to test staff once a week instead of twice a week. Ohio's testing guidelines specify that all SNFs in the state must test staff twice a week, but as we reported previously, the Health Department (ODH) declared that they would not enforce the more stringent state guidelines. In a positive sign not yet reflected in the CMS positivity data, Ohio's total COVID-19 cases were below 5,000 each of the last two days.

ODH Phase 1A Guidance. ODH issued guidance to vaccine providers about how they should handle vaccinations for Phases 1A and 1B. After noting that hospitals were directed to stop delivering first vaccine doses to their employees yesterday and to start vaccinating the Phase 1B population, ODH wrote:

Local health departments should continue to vaccinate eligible and willing Phase 1A priority populations with first and second doses as Phase 1B begins. Local health departments that continue to vaccinate Phase 1A priority populations will continue to receive vaccine that should be used for those populations. If a local health department has unused vaccine after it completes Phase 1A vaccinations, it may use the remaining vaccine to vaccinate eligible Phase 1B priority populations.

Phase 1B enrolled providers who are contacted by Phase 1A priority populations for vaccination should explain that you are not permitted to vaccinate them under the state’s COVID-19 vaccination guidance which requires your vaccine allocation to be used exclusively for Phase 1B priority populations. Direct them to contact their local health department to see if they are a Phase 1A priority population and still eligible for vaccination.

CMS Responds to Follow-up Questions Related to New COVID-19 ICD-10 Codes and Coding Guidance. The following article is by AHCA/NCAL's Dan Ciolek.

Recently, new ICD-10 codes were introduced off-cycle for COVID-19 effective January 1, 2021 and CMS posted updated coding guidance when there was a COVID-related condition. Additionally, CMS updated the PDPM Mappings file to incorporate the newly introduced codes. Some of the new COVID-19 related codes map to RTP and cannot be used as primary reason for SNF stay in item I0020B of the MDS. Several members have raised concerns about coding on a PPS 5-day or IPA assessment if the patient has previously tested positive for COVID and was symptomatic but since then they have tested negative, but needs skilled care due to a COVID-related condition (i.e. pneumonia). AHCA asked CMS to clarify and they provided the below response. AHCA recommends that you forward this information to MDS assessment and billing staff. We have requested tht CMS add this clarification to their published COVID-19 guidance which make some time due to clearance processes so we are sharing this information in the meantime. Let me know if you have questions.

When we updated the ICD-10 code mappings for the SNF PDPM clinical categories effective 1/1/2021, we added four new codes related to a diagnosis of COVID-19 to the Return to Provider (RTP) category. Specifically, code J1282, Pneumonia due to coronavirus disease 2019; code Z1152, Encounter for screening for COVID-19; code Z20822, Contact with and (suspected) exposure to COVID-19; and code Z8616, Personal history of COVID-19, were added to the code mappings.

These RTP codes cannot be used as a primary diagnosis code for a Part A SNF patient. However, in some cases, a patient may receive a diagnosis of pneumonia due to COVID-19 (J1282), which becomes the primary reason for their SNF stay, even after the patient subsequently tests negative for COVID-19. In these cases, as long as the patient still has COVID-associated pneumonia, code U07.1 should continue to be assigned, and U07.1 would be sequenced first. Code J1282 cannot be sequenced first.

This is in accordance with the "code first" guidance in the ICD-10-CM Official Guidelines for Coding and Reporting (available online at www.cms.gov/files/document/... ) :

1. (i) Pneumonia For a patient with pneumonia confirmed as due to COVID-19, assign codes U07.1, COVID-19, and J12.82, Pneumonia due to coronavirus disease 2019

Regardless of whether the patient's most recent COVID test is positive or negative, code U07.1 should continue to be assigned as long as the patient has a current, acute manifestation of COVID, such as pneumonia.

I hope this addresses your questions regarding the pneumonia code J1282 and coding for pneumonia diagnoses that are manifestations of a COVID-19 diagnosis that has become negative.