CMS County-Level Positivity. The Centers for Medicare and Medicaid Services (CMS) published their latest county-level COVID-19 test positivity data today. The Ohio table remains essentially static. The only change from last week was Highland County moved from red to to yellow despite a 21% positivity rate because the county fell three tests short of the minimum. Despite the decline in total new cases in the state (today's number was 4,334), CMS shows only three counties as having positivity rates below 10%. The CMS positivity ratings apply to SNF testing and visitation. We recommend centers in red counties, which are prohibited from holding routine indoor visitation, explore offering compassionate care visits to as many qualifying patients as possible, including patients with COVID-19.

HHS Makes November QIP Payments. Today, the Department of Health and Human Services (HHS) began making SNF Quality Incentive Program (QIP) payments for November 2020. AHCA/NCAL believes these payments will come out over several days, so if you did not receive one today, it may not mean your facility is ineligible. HHS did not issue an announcement about this payment or any information about the totals paid by state or to individual providers. They did send an email to providers who received payments explaining that they were for the November QIP allotment, so presumably they do not include the December or wrap-up distributions. HHS also has not released any statements relative to the Phase 3 General Distribution. Today's payments, however, are a positive sign that the Biden Administration does not intend to shut down Provider Relief Fund distributions committed by the previous Administration.

HHS Likely to Extend Public Health Emergency Further. According to a letter Acting HHS Secretary Norris Cochran sent to Governors, HHS intends to renew the COVID-19 Public Health Emergency (PHE), which currently expires April 20, 2021. The Acting Secretary wrote, "[t]o assure you of our commitment to the ongoing response [to COVID-19], we have determined that the PHE will likely remain in place for the entirety of 2021, and when a decision is made to terminate the declaration or let it expire, HHS will provide states with 60 days' notice prior to termination." The letter goes on to mention the various waivers (telehealth is listed specifically) that are based on the PHE, extension of enhanced federal Medicaid funding, and applicability of the Public Readiness and Emergency Preparedness (PREP) Act as benefits of continuing the emergency declaration, although CMS could end some of the waivers before the PHE expires.

Updated PPP Loan Forgiveness Application. The Small Business Administration published an updated version of the application that Paycheck Protection Program (PPP) loan recipients can use to apply for forgiveness of the loan under the program's requirements. The new version reflects changes Congress made in PPP through the Consolidated Appropriations Act, 2021.

Vaccine News; CDC Guidance Changes. The Department of Health (ODH) published a new version of their Phase 1B vaccine provider guidance. In addition to incorporating last week's clarification of when people with intellectual and developmental disabilities are included in Phase 1B, the guidance reiterates:

 Local health departments should continue to vaccinate eligible and interested Phase 1A priority populations including non-hospital affiliated healthcare workers, congregate care residents and staff, and nursing homes or assisted living facilities not enrolled in the federal long-term care pharmacy program at the same time vaccinations are under way for Phase 1B. Local health departments that continue to vaccinate Phase 1A priority populations will continue to receive vaccine for those populations, and any remaining vaccine can be used to vaccinate eligible Phase 1B populations.

ODH further states, "Phase 1B enrolled providers who are contacted by Phase 1A populations, such as hospital healthcare workers or non-hospital healthcare workers, for vaccination should explain that the state’s COVID-19 vaccination guidance requires their allocation to be used exclusively for Phase 1B populations." The guidance contains other relevant information for Phase 1B vaccine providers.

ODH also published a new edition of their Ohio Vaccine Preparedness Office Weekly Update. One of the notes in the newsletter points out the latest (January 21) revisions of the key Centers for Disease Control and Prevention (CDC) guidance on vaccination, "Interim Clinical Considerations for Use of mRNA COVID-19 Vaccines Currently Authorized in the United States." The most important changes are:

• A six-week end point for the permissible gap between first and second doses. This interval previously was not limited.
• Allowance for mixing doses of the two vaccines "[i]n exceptional situations in which the first-dose vaccine product cannot be determined or is no longer available ...."
• Updated language on the interaction of SARS-CoV-2 infection with vaccination, including the statement, "[f]or vaccinated persons who subsequently develop COVID-19, prior receipt of an mRNA COVID-19 vaccine should not affect treatment decisions (including use of monoclonal antibodies, convalescent plasma, antiviral treatment, or corticosteroid administration) or timing of such treatments."
  

Required Reading: DODD Health and Welfare Alert. The Department of Developmental Disabilities (DODD) published Health and Welfare Alert 68-1-21, which provides information about COVID-19 vaccination, including Dr. Laura Sorg's video answering questions and a facts-vs.-myths table. DODD's rules require all ID/DD employees to review Health and Welfare Alerts as part of their annual training.

Other DODD COVID-19 Updates. DODD released an update with several important pieces about COVID-19 for ID/DD members. It includes a video message from Director Jeff Davis on Phase 1B of Ohio's vaccination plan, DODD's vaccination toolkit (focusing on education), a panel discussion for families on Wednesday hosted by Dr. Sorg, the value of monoclonal antibodies for people with ID/DD who contract COVID-19. Please see the update for more information on these topics and for registration information for the panel.

Provider Relief Fund Reporting Registration Updates (from AHCA/NCAL). HHS recently launched the Provider Relief Fund (PRF) Reporting Portal, which is only open for providers to set up user accounts and register to submit reports. Currently, HHS has not established a registration deadline or set a due date for first reports. The original due date was February 15, but that has been pushed back to a date still to be determined.  

If you are experiencing issues after reviewing the Reporting Registration FAQs and contacting the Provider Support line at (866) 569-3522, note that HHS has not set a deadline for registration.  

The current open-ended registration window gives AHCA/NCAL time to address the registration glitches with HHS , as well as several other challenging registration features such as having a unique username and email address for each TIN. If you have questions, suggestions or recommendations for other changes to the registration guidance, please email covid19@ahca.org.

AHCA/NCAL Encourages Members to Report Vaccination Data to NHSN. Reporting of data to the National Healthcare Safety Network (NHSN) through the Surveillance for Weekly HCP & Resident COVID-19 Vaccination module currently is voluntary. AHCA/NCAL, however, asks all members to report. Dr. David Gifford explained that CDC and CMS will use the long-term care specific data from NHSN, not data reported to broader state vaccination systems such as Ohio's Impact Statewide Immunization Information System (ImpactSIIS), to analyze whether various restrictions should be lifted because of levels of vaccination and of COVID-19 cases in facilities. Decisions on lifting restrictions are not likely at least until the Pharmacy Partnership for Long-Term Care clinics are completed, but robust data will help expedite them as much as possible.