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January 5, 2021

Vaccine Safety Educational Efforts Tomorrow. Tomorrow at 4:00 p.m., the Centers for Medicare and Medicaid Services (CMS) and the Centers for Disease Control and Prevention will hold another national fireside chat about the safety and efficacy of the COVID-19 vaccines. As was the case last week, tomorrow's program will be directed at facility staff and will be intended to address their questions and concerns, as well as myths about the vaccines. You may register for the session at this link. No live questions will be taken, but they can be submitted in advance to

In addition, Ohio will continue their series of round tables for staff tomorrow at 8:00 a.m., 2:00 p.m., and 6:00 p.m. Please see this flyer for more information and for registration links.

In his press conference today, Governor Mike DeWine mentioned the round tables and commented on the Pharmacy Partnership for Long-Term Care. The Governor's Office release summarized the latter part of the Governor's remarks:

As of Sunday, approximately 61 percent of nursing homes in Ohio have been visited by a pharmacy vaccine provider. Of those locations, only approximately 40 percent of staff members have chosen to receive the vaccination. Of nursing home residents, approximately 75 to 80 percent of residents have decided to receive the vaccine.

Nursing home staff and residents who have received their first dose of vaccine will begin receiving second doses on Friday. Governor DeWine encouraged those in nursing homes who initially declined to receive the vaccine to get their first dose as part of this second round. Following this opportunity, it may be some time before a first dose is available again.

ODH Will Not Enforce State Testing Frequency on Survey. Today, Rebecca Sandholdt of the Department of Health (ODH) announced that surveyors will not cite SNFs for failure to comply with the state COVID-19 testing guidelines, so long as the facility meets the federal testing requirements. As a practical matter, what this means is ODH will not cite a SNF located in a CMS yellow county (see current table) that tests staff weekly, as required by CMS, but not twice a week, as specified by the state guidance. Two key caveats: 1) CMS mandates outbreak testing, so a SNF can be cited for failure to conduct outbreak testing per the CMS guidelines; 2) CMS requires a facility to continue testing at the higher frequency for 14 days after a county moves to a lower frequency (e.g., red to yellow). Ms. Sandholdt emphasized that SNFs still should comply with the state testing guidelines, but both she and ODH attorney Heather Coglianese stated that the survey agency cannot enforce them. Ms. Sandholdt added that ODH does not enforce the state testing guidelines under licensure either.

Although Ms. Sandholdt did not address residential care facilities (RCFs) specifically, her comment about licensure suggests that ODH will not enforce the RCF testing guidelines either. We recommend assisted living members not change their testing frequency until we confirm this assumption with ODH.

The only statutory enforcement mechanism for orders of the Director of Health is criminal prosecution under sections 3701.352 and 3701.99 of the Revised Code, a highly unlikely event relative to a difference in testing frequency.

CMS Reduces FIC Requirements, Addresses Annual Surveys. Yesterday, CMS issued a revised version of Quality, Safety, and Oversight QSO letter 20-31-All, which originally came out on June 1, 2020. This QSO deals with survey activities during the COVID-19 pandemic, most notably Focused Infection Control surveys (FICs) of SNFs. Yesterday's changes to the QSO significantly narrow when CMS requires FICs. Ms. Sandholdt explained that this week, instead of 270 FICs, CMS under the changes is requiring only 37. The QSO also contains an extensive set of questions and answers about resumption of annual surveys - specifically, how annual surveys are to be performed during the pandemic. It should be noted that the changes to the QSO do not alter the standard for when states must resume standard surveys of both SNFs and ICFs/IID: when the state reaches Phase 3 of CMS's SNF reopening guidance. Ohio is far from being in this position. The QSO also does not change the requirements for investigating 2-day and 10-day complaints.

RCF Annual Surveys. Ms. Sandholdt also noted OHCA's request that ODH pause RCF annual surveys because they are not required by CMS but take up surveyor time. She said ODH scheduled RCF annuals as a training ground for new surveyors, but the latest class of surveyors instead will be shifted to helping with complaint surveys and FICs in SNFs. ODH will continue to conduct complaint visits to RCFs, but we should see annuals "drastically decrease."

Key Take-Aways from Impact SIIS Webinar. Today, ODH held a webinar to explain how vaccine providers will report COVID-19 vaccination administration data in the Impact SIIS database. Information will be linked to patient profiles, and target population as well as occupational data are required for each vaccine recipient. Registered providers also will be able to search which vaccine a patient or staff member received on the first dose to ensure the same type of vaccine is delivered on the second round. There are three methodologies for submitting information to Impact SIIS:

  1. Utilize a Health Level-7 (HL7) interface with your current electronic health record. While this is ODH's preferred method, long-term services and supports providers typically will not have a HL7 interface. If you are a registered vaccine provider and wish to set up such an interface, please email
  2. Direct data entry into Impact SIIS. This method would be best for providers who are not running mass clinics and do not have an HL7 interface.
  3. Mass clinics may upload a data file on daily basis during phase 1A. This too is likely not a viable option for OHCA members in the future. 

It is important to note that only the administering provider is required to report vaccinations.

To facilitate possible methods for delivering vaccine in the future (for instance, when the Pharmacy Partnership for Long-Term Care is over in a few weeks), we strongly encourage all members to register as vaccine providers as soon as possible. ODH indicated that they have received several hundred applications and generation of Impact SIIS login information is backlogged. Below are links to additional resources provided during today’s webinar:

You also may wish to review this week's Ohio Vaccine Preparedness Office Weekly Update. While primarily targeted to vaccine providers, there may be some items of general interest.

COVID-19 Healthcare Operating Loss Loans in Stimulus Package (from AHCA/NCAL). Nursing homes, assisted living communities, and centers for individuals with ID/DD are facing unprecedented challenges trying to prevent further spread of the COVID-19 pandemic, which is putting additional strain on their operations and bottom-line cash flow. Long term care (LTC) employees are on the frontline of this crisis, making personal sacrifices and voluntarily placing themselves in harm’s way to protect and provide quality care for someone’s mother, father, grandfather, grandmother, family member, or friend who is unable to live on their own and relies on the assistance of others. To assist our senior housing and LTC facilities across the country, AHCA/NCAL asked Congress and the U.S. Department of Housing and Urban Development (HUD) to support a provision in the stimulus package that the President recently signed into law that permits HUD to finance up to one year of operating losses for certain hospital and residential care facilities insured by the Federal Housing Administration (FHA) under Sections 232 and 242 of the National Housing Act.  The Association asked for this proposed relief so providers can continue to focus their full attention on ensuring the residents and staff of their buildings remain safe from COVID-19.

Specifically, this stimulus bill provision allows existing participants in the Section 232 program to borrow funds under FHA 223(d) to cover losses or additional expenses as a result of COVID-19. Loan proceeds can cover up to a year of principal and interest payments for the underlying FHA loan, mortgage insurance premiums, deposits to reserve accounts, as well as property taxes and insurance. Facilities must have been financially sound prior to March 13, 2020 and have exhausted all other forms of assistance in order to qualify. 

For those providers that are interested, please contact your FHA lender as the mortgagee will make an application on behalf of the facility/borrower. More information on FHA can be found here

Updated HCIC List. With the surge of COVID-19 cases over the last couple of months, ODH and the Department of Medicaid approved a number of additional Health Care Isolation Centers (HCICs), now totaling 32 centers with 934 beds. Please see the list of HCICs, updated as of December 28, 2020.

Reminder: Ensure You Have Correct Contact Information in EIDC. The dizzying frequency of new information, much of which comes through ODH's Enhanced Information Dissemination and Collection system (EIDC), makes it important that the material comes to the correct mailbox. Ms. Sandholdt asked us to remind members to make sure the contact information in EIDC routes the messages to the correct person.