Medicaid SNF rates out. Is it COVID-19-related? No. Do you care? We suspect you do, if you operate a SNF. Today the Department of Medicaid (ODM) released SNF rates for the period beginning July 1, 2020, and later posted them. The statewide average July 1 rate is $209.14, almost $7 per day (3.5%) more than the June 30 rates. The average "new" quality incentive payment, labeled "5165.26" on the table, is $9.65 for all providers, including the 227 centers that received no incentive because of changes of operator, new building openings, or the occupancy penalty. The average incentive for centers that qualify is $12.65. Each point appears to be worth $0.85.

Additional counties turn red; facility COVID-19 cases up again. Today's refresh of the new, color-coded Public Health Advisory System shows that six additional counties (Lorain, Wood, Pickaway, Fairfield, Clermont, and Summit) are now in the red category, while Huron County was downgraded to orange. Hamilton, Butler, and Cuyahoga Counties are asterisked as approaching the highest level, purple, and Franklin County was relieved of its asterisk but remains red. Masks are required in public in red counties. The latest statistics on facilities (ICFs/IID, assisted living communities, and SNFs) showed an increase in current cases among both residents and staff for the second straight week, with the state total now standing at 1,161.

Palmetto confirms Ohio RCD resumption August 31, 2020. On March 30, 2020, the Centers for Medicare and Medicaid services (CMS) announced a pause of certain claims processing requirements for the Review Choice Demonstration (RCD) for home health services in Illinois, Ohio, and Texas until the Public Health Emergency (PHE) for the COVID-19 pandemic ends. Last night, CMS announced that they will resume RCD regardless of the status of the PHE. For Ohio providers, Palmetto GBA confirmed these important timeframes:

• August 3, 2020: The second choice selection period will reopen for Ohio home health agencies. 
• August 17, 2020: The second choice selection period will close.
• August 31, 2020: Home health claims with billing periods beginning on or after August 31, 2020, will be subject to review under the requirements of the choice selected. 

Following resumption of the demonstration, Palmetto GBA will conduct post-payment review (additional documentation request or ADR) on claims that were submitted and paid during the pause without review. Providers who continued to submit Pre-Claim Review (PCR) documentation will not receive an ADR on any of those paid claims. None of the PCR affirmations, however, will count toward the 6-month demonstration period for the second choice selection. Palmetto GBA will host a free webinar about RCD resumption on August 5, 2020, at 11:00 a.m. Interested providers may register here.

For additional questions regarding your selection choices or affirmation rates, please contact Erin Begin.

Applicability of interpretations in yesterday's Update. We apologize that the material in yesterday's COVID-19 Update was not clear about the facilities to which it applies. Here are some clarifications:

• The Director of Health's fourth amended order on visitation and related matters applies to SNFs, assisted living communities, and ICFs/IID, except for certain provisions that are labeled as covering only to the first two facility types.
• The state's interpretation (by the Director of Aging) that the Public Health Advisory System does not mandate stopping visitation regardless of a county's color level applies to all three types of facilities, even though the interpretation came from Aging.
  
• The interpretation about beauticians and testing is relevant only to SNFs because at this time, employee testing is not required in ICFs or assisted living.
  
• The guidance from the Centers for Disease Control and Prevention on quarantining new admissions is mandatory only for SNFs. The relevant guidance is entitled, "Preparing for COVID-19 in Nursing Homes." Other providers should consider whether and to what extent they should apply the guidance to their admissions, but it is not required for them.
  
• The status report on audits for State Fiscal Years 2017 and 2018 also applies only to SNFs. We have not received a similar update on ICF audits, although we suspect they are affected similarly.
  

Adult Day/Vocational Habilitation survey. The Ohio Association of County Boards of DD (OACB) surveyed service and support administrators (SSAs) to get information on how many people previously receiving facility-based Adult Day or Vocational Habilitation services have resumed those services or are planning to resume services by August 1, 2020. OACB shared the results of the survey with OHCA. As of June 25, 23.1% of people included in the survey who previously received day services had resumed services and another 23.8% were planning to re-start services by August 1. The main reasons for not resuming facility-based day services were 1) health and safety concerns and 2) lack of provider capacity. Interestingly, lack of transportation was fourth behind lack of interest in returning.

However, the Terms and Conditions for all Provider Relief Fund payments also require recipients to submit any reports requested by the Secretary that are necessary to allow HHS to ensure compliance with payment Terms and Conditions. HHS will be requiring recipients to submit future reports relating to the recipient’s use of its PRF money. HHS will notify recipients of the content and due date(s) of such reports in the coming weeks.

To our knowledge, HHS has not done this yet. HHS, however, did add a few more questions and answers (dated July 8, 2020) to its document.

When a staff person is assigned to an HCIC unit, they must be dedicated to that unit on that calendar day. If the facility has adequate PPE and the PPE is used appropriately, they can be scheduled to work in a different portion of the nursing home on other calendar days.