State Rolls Out Repeat SNF Staff Testing. Representatives of the Departments of Health and Medicaid (ODH and ODM) presented a webinar for providers this morning that outlined the state's (basically, Governor Mike DeWine's) decision to substitute repeat staff COVID-19 testing for the previously announced all-resident testing. ODH's Rebecca Sandholdt said the initial round of staff testing will finish Friday, and the first repeat round will begin Monday. After that, the "cadence" will be every two weeks. The state will provide a schedule for SNFs to conduct their own testing, but they have not completed the schedule. Testing must be done in a single, 24-hour span, based on training the state will provide. The first round will utilize the familiar polymerase chain reaction tests, but the state hopes to switch to antigen point-of-care tests as soon as possible. As before, providers can opt out of the state-supported testing. Quest Diagnostics and certain state labs will do the analysis. ODM's Marisa Weisel admitted that while they are working on the turn-around time problem, it is not solved. The state's webinar did not address payment for the staff testing, but Ms. Weisel emphasized correctly completing the insurance information on the applicable lab requisition. She later said the payment issue will be addressed in a frequently-asked questions document and updated testing guidelines, but neither those documents nor the recording or slides from the webinar is available yet. OHCA members posed a number of specific questions about the repeat testing to which we will attempt to get answers.
Assisted Living to Join Mass Testing World. In an early morning meeting today, Director Ursel McElroy of the Department of Aging (ODA) said she plans to begin a testing program for residents and staff of assisted living (AL) communities starting the week of August 9. Although there will be some similarities to the SNF testing occurring at the same time, there are some important differences. The AL program will use oral instead of nasal swabbing and will be voluntary for providers. Director McElroy strongly encouraged all AL communities to participate. The baseline testing will be both staff and residents, with subsequent rounds only staff. While laboratories and a portal will be used, the cost of at least the first two rounds of testing will be covered by the department, and insurance information will not be collected. Director McElroy said ODA will offer two webinars early next week, the first for facility leadership and the second to train people who will oversee the swabbing.
US Senate Releases Stimulus Legislation. Senate Republicans circulated a draft set of nine bills collectively known as the Health, Economic Assistance, Liability Protection, and Schools (HEALS) Act. As expected, the $1 trillion package of bills includes liability protection that would apply broadly to all types of health care providers, explicitly including home and community-based waiver providers. Among many other provisions, the legislation also would add $25 billion to the Provider Relief Fund and $16 billion for COVID-19 testing, plus would allow providers who received accelerated and advanced Medicare payments another 150 days before having to start repaying the debt. The legislation would expand the Paycheck Protection Program and would extend telehealth provisions. The HEALS Act differs in many ways from a $3 trillion Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act passed in May by the House of Representatives. The two sides have until August 7, when summer break begins, to iron out their differences and to pass an agreed bill.
Coronavirus Relief Fund Notes. During yesterday's Office of Budget and Management webinar on the Coronavirus Relief Fund (CRF) payments to health care providers, we noted several points to share with members before the promised updates to the state's frequently-asked questions document comes out.
- State officials made conflicting statements about how a company should apply for multiple provider entities they operate. Our opinion remains that the safest course is to complete a separate application for each provider.
- Department of Developmental Disabilities Director Jeff Davis clarified that ICFs/IID should report the CRF payments as revenue and should not offset costs on their calendar year 2020 cost reports. They also must track detailed expenditures and lost revenue related to COVID-19 to be able to demonstrate costs above their current Medicaid per diem rates for the current year in case of an audit.
- In a correction to the original slides, OBM now says they require a Dun and Bradstreet DUNS number as part of the application.
- OBM provided an email address for individual provider questions: crfprovider@obm.ohio.gov.
- There was discussion on the webinar about permissible and impermissible expenditures of CRF money (e.g., hazard pay), based on relatiely brief Treasury Department guidance and frequently-asked questions. More federal guidance on use of funds under the Coronavirus Aid, Relief, and Economic Security (CARES) Act that should shed more light on this subject is expected in August.
- OBM's Stacie Massey said she hopes payments will be made "in a few days" after application, if the provider's identifying information is validated.
- The wording in the portal, "home health waiver," is incorrect, as Medicaid home health and private duty nursing services are covered, along with home and community-based waiver services, except services for people with intellectual and development disabilities. (We continue to advocate for reversal of this omission.)
- Medicaid Director Maureen Corcoran said the goal is to make one payment to a single provider, even if different portions of the funding were approved at different times. This principle includes the infection control incentive payments to SNFs.
- Ms. Massie suggested in the webinar that Medicare and Medicaid revenue could be considered a federal award that would trigger executive compensation reporting. We continue to believe this is not the case.
DODD Issues MUI Alert. Today, the Department of Developmental Disabilities (DODD) issued a Health and Welfare Alert for Reporting MUIs during COVID-19. This Health and Welfare Alert shares major unusual incident (MUI) data trends from March 1 to May 31, 2020. The report also identifies possible causes and contributing factors for the reduction of reported MUIs. As a reminder, DODD's rule 5123-17-02 requires all developmental disabilities employees to review Health and Welfare Alerts released by DODD as part of annual training.