Elevating the Post-Acute and
Long Term Care Profession

July 15, 2020


More on Ohio SNF resident testing. In case you missed the state's webinar kicking off mandatory testing of all SNF patients, here are the slides and recording from the program. Much of the content was the same as the previous staff testing webinars, with some adjustments for the new subject matter. There were three changes from yesterday's discussion reported in our COVID-19 Update.

  • The begin date for opt-out testing is July 3 instead of June 6. This reduces the number of centers that can opt out based on past testing.
  • The webinar suggested that multiple laboratories will be used instead of Quest Diagnostics handling all the testing. We learned after the webinar that Quest is still the plan, but the state officials wanted to leave wiggle room in case they need to involve other labs for sufficient capacity.
  • Resident testing dates will not start until early August, after all of the staff testing is completed. This means the idea of combining staff and residents under the new program in Zone 1 is not happening.
Aside from those changes, here are a few other notes from the webinar that we considered worth sharing:
  • Slide 15 in the slide deck has a diagram of what a facility should do if it is short of personal protective equipment (PPE).
  • This Friday - July 17 - is the last date for finishing opt-out staff testing. The letter with the results must be submitted by July 31.
  • For the resident testing, the laboratory requisition forms should be completed in advance of the testing date. 
  • Facilities should use teams of two to swab, and the swabbing and packaging of specimens for pick-up must be completed within 24 hours.
  • As with the staff testing, a patient who previously tested positive does not need to be re-tested.
  • Swab pick-up will be by the National Guard, courier, or facility-contracted shipping company. The state will inform the center of which option applies to them.
  • Anterior nares swabbing will be used, as in the staff testing program.
  • There is no final decision on re-testing staff.
At the end of the webinar, Medicaid Director Maureen Corcoran discussed the Health and Human Services (HHS) point-of-care testing announcement from last night.

More information on point-of-care testing. Centers for Medicare and Medicaid Services (CMS) Administrator Seema Verma and Dr. Brett Giroir, Assistant Secretary of HHS, held a special call for AHCA members about their plan to supply free point-of-care (POC) testing devices to all SNFs in the country. The information they provided largely reflected the contents of yesterday's news release, but they provided some additional details.

To utilize one of the machines, a SNF must have a waiver under the Clinical Laboratory Improvement Amendments (CLIA). The Department of Health (ODH) shared today a list of all waivered SNFs, which includes 957 centers (presumably all or almost all SNFs in Ohio). If you are not sure if your facility is waivered, we can check for you. The first 1,500-2,000 machines should be shipped out by the end of next week. CMS will determine which centers will receive them based on being in hot spots and the number of cases reported to the National Healthcare Safety Network. After 6-8 weeks, most SNFs in the country will have received devices. The machine will be accompanied by a supply of tests estimated to last 6 weeks, assuming weekly testing of staff (an average of 400 tests per building, depending on size). Additional tests are expected to cost about $25 each, much less than the laboratory tests. Because they are antigen tests, the POC tests are more suitable for surveillance than for diagnosis, and anyone suspected to have COVID-19 should be re-tested with a polymerase chain reaction test if they test negative.

It is not clear at this time how these machines, if Ohio SNFs receive any of them, will fit into the state's testing program.

Frequently-asked questions about orders and guidelines, part one. Here are a few questions that came up in Tuesday's SNF member call and via emails from members. We will address more in the next COVID-19 Update.

  • Are CDC guidelines recommended or required for SNFs? They are required by the certification regulations, specifically 42 CFR 483.80(a)(1), which specifies that a SNF's infection control program is responsible for "following accepted national standards ...." In the area of infection control, no one can reasonably dispute that CDC's guidelines are the accepted national standards.
  • Can window visits be conducted with the window open? No, an open window essentially converts the visit into an inside visit because droplets easily can pass into the interior of the building. Currently only outside visits (where both the visitor and the resident are outdoors) are permitted by the fourth amended ODH visitation order for ICFs and assisted living and starting next Monday for SNFs (pending staff testing). The CDC guidance on supporting your loved one in a facility refers to visits "through a glass window or a parade of cars."
  • Is full PPE required to care for a new admission whose COVID-19 status is unknown? Yes, CDC guidance (as enforced by ODH) specifies, "HCP should wear an N95 or higher-level respirator (or facemask if a respirator is not available), eye protection (i.e., goggles or a face shield that covers the front and sides of the face), gloves, and gown when caring for these residents." While the guidance uses the word "should" instead of "must," that is the typical way CDC words its guidelines when giving the agency's position.

Recoupment of advanced/accelerated payments looming. Providers who took advantage of the advanced/accelerated Medicare payments CMS provided in March and April of this year to assist with cash flow will begin to see recoupment of those funds in the next few weeks. Providers continued to receive full claim payments for 120 days after the advanced/accelerated payment. At the end of the 120-day period, the recoupment process begins, and every claim submitted by the provider will be offset to repay the accelerated/advanced payment. This process is automatic. SNF, home health, and hospice providers will have up to 210 days for recoupment. The Medicare Administrative Contractor (MAC) then will perform a manual check to determine if there is a balance remaining, and if so, it will send a request for repayment of the remaining balance, which is collected by direct payment. Interest will not accrue until the uncollected balance has been demanded. Providers may submit a voluntary refund at any time. For more information, please refer to the CMS fact sheet, the Palmetto GBA FAQs, or the CGS Accelerated/Advanced Payment website. It is possible that the fourth federal stimulus bill, which we expect to be finalized in mid-August, will extend the terms of the recoupment and reduce the interest. According to AHCA, however, there is no chance repayment will be forgiven.

CMS will not accept Joint Commission virtual recertification surveys. On a call today, ODH's Rebecca Sandholdt said CMS does not approve or honor Joint Commission virtual re-accreditation surveys for Medicare recertification purposes. The Joint Commission has conducted virtual surveys since June 1, 2020. ODH recertification surveys are still on hold. ODH also shared that resumption of non-long-term care complaint surveys, which include Focused Infection Control surveys, has not generated any specific trends in citations.

UNC and Google create app to support mental health of frontline healthcare workers. We saw this app promoted through various media outlets over the past two days and wish to bring you the following excerpt from the Google Cloud Blog.

The COVID-19 pandemic has put a huge strain on the U.S. healthcare system and its people. First responders and healthcare workers on the frontlines face incredible challenges, both physical and mental. Healthcare workers were vulnerable to depression and suicide before COVID-19. Now the problem is more acute, with first responders and frontline healthcare workers reporting alarming rates of depression, anxiety, insomnia, and distress.

To help these workers cope with the stressors of the COVID-19 pandemic and the impact they have on their mental health, researchers and clinicians at the University of North Carolina created the Heroes Health Initiative in partnership with Google Cloud. The Heroes Health app is available free of charge through Google Play and Apple’s App Store to any healthcare worker in the United States, with additional features for healthcare institutions that want to deploy it across their organizations.  

For individual healthcare workers, the Heroes Health app delivers short mental health self-assessments each week, and displays symptom summary reports to help them better understand the state of their own mental health - and changes over time. The app also provides links to immediate support and mental health resources, emphasizing free and low-cost services.

Tomorrow! Free Relias webinar on self-care during COVID-19. Often discussed and infrequently practiced, self-care is critically important during the profound and protracted COVID-19 pandemic. In addition to the understandable and normal waves of anxiety, depression, and stress that many feel during this uncertain time, the COVID-19 pandemic renders us more vulnerable to burnout, compassion fatigue, or vicarious trauma. On Thursday, July 16, beginning at 3:00 p.m., Relias will offer a complimentary webinar to discuss the reasons why COVID-19 both challenges our resilience and offers an unprecedented opportunity to incorporate self-care into our lives. Learn more about the featured speakers and register by clicking here.


With Support from OHCA Champion Partners