Key clarifications of visitation order. Director of Aging Ursel McElroy provided two important clarifications relating to the Director Health's fourth amended order on visitation and related matters at SNFs, assisted living communities, and ICFs/IID. The Director addressed two specific questions posed by OHCA.
NF Order and relation to Governor’s Ohio Public Health Advisory System:
The Governor’s recently released Ohio Public Health Advisory System, with four (4) different levels of risk, is a color-coded system designed to supplement existing statewide Orders, including the recently amended Fourth Amended Director’s Order to Limit Access to Ohio’s Nursing Homes and Similar Facilities, with Exceptions (Order), released July 2, 2020.
When determining the appropriateness of scheduling outdoor visitation for residents, facilities should use the Ohio Public Health Advisory System to assist in developing a comprehensive plan for outdoor visitation, as well as considering all implications for resident physical and mental well-being, as required in 8(a)(i) and (ii) of the Order.
For instance, during periods of high risk levels, facilities may consider limitation of outdoor visitation for residents, on a case-by-case basis. However, it must be noted that none of the currently identified risk levels require outdoor visitation to be completely terminated.
Hair Salons:
The Order does require screening of all individuals and staff entering a facility, which extends to hair salon staff. However, nothing currently requires testing of this staff. It is highly recommended, that to the extent testing is feasible and available, each facility test these individuals prior to re-entering facilities for the first time.
We have a couple of additional requests in to Director McElroy based on members' inquiries.
Clarification on Admission Quarantine. As noted yesterday, OHCA probed the Department of Health (ODH), Bureau of Infectious Disease, on their interpretation of when a patient being admitted to a facility is considered to have an unknown COVID-19 status, particularly if the patient was tested before admission. Under recently revised Centers for Disease Control and Prevention (CDC) guidance, patients with unknown status must be quarantined for 14 days in a private room and cared for by staff wearing full personal protective equipment, including N95 respirators. The guidelines do not define unknown, but Health defined it as not being known to be positive. ODH's Sarah Mitchell said she would ask the question of CDC, who provided the following response that backs ODH's interpretation:
Thank you for contacting us for clarification about the nursing home guidance.
The term unknown status in the context of this guidance, describes anyone who has not tested positive – this could include those who have tested negative as well as those who have never been tested.
In regard to testing, the following recommendations should be considered:
- For those who are known or suspect COVID + (from the NH guidance)
- Newly admitted and readmitted residents with confirmed COVID-19 who have not met criteria for discontinuation of Transmission-Based Precautions should go to the designated COVID-19 care unit. When testing +/suspect patients to lift TBP the two tests can be conducted at the hospital or LTCF.
- Newly admitted and readmitted residents with COVID-19 who have met criteria for discontinuation of Transmission-Based Precautions can go to a regular unit.
- For those with unknown status, LTCFs should adhere to the 14 day period upon readmission/new admission.
When plied with additional questions, Ms. Mitchell provided a detailed response discussing the relationship of testing and quarantine.
ODM updates on multiple issues. Julie Davis of the Department of Medicaid (ODM) shared the following brief update, in lieu of the regular monthly meeting with the provider association:
Rates – under development and hope to be finalized this week. If providers bill for resident deaths or discharges before the rates are loaded, their claims will be held/suspended and processed once their facility rate is loaded in the next few days.
PDPM – ODM appreciates the input from the associations and will be providing a response in the near future.
NF Vent Rates – rates increased effective July 1 and the NF Fact Sheet reflecting that increase was posted on ODM’s website.
Eligibility redeterminations – redeterminations have resumed, but ineligible individuals will not have their benefits ended unless they specifically ask.
Pending applications - down to 820 over 180 days. Approximately 3,900 are pending over 45 days.
HCICs - 12 NFs have been approved as Health Care Isolation Centers, with 7 designated as Isolation Providers, 3 as Quarantine, and 2 specializing in both.
Billing instructions were distributed a couple of weeks ago and will be posted on a new HCIC webpage being developed.
CMP electronic communication device project – Nearly all of the 582 facility applications have been reviewed, with the remaining requests being reviewed this week. Approved providers are in the process of submitting receipts needed by ODM to issue reimbursements. Fewer than 10 applications have been denied.
Patient Liability Recalculations – increases in Patient liability are not being processed at this time, but decreases should be processed.
In addition, Mark Graves of ODM emailed SNF providers this information about upcoming audits:
I’m sure you’re aware that ODM paused several of its external facing-interactions to allow certain providers and their partners to adequately address the many pandemic-related issues. One of those paused functions is the issuance of the fiscal years 2017 & 2018 overpayment reports. ODM is currently reviewing those reports to ensure the leanest versions possible will be emailed to you at the appropriate time.
ODM is assessing conditions monthly regarding the impact and timing of the release of these reports and will let you know when the decision has been made to move forward.
Please feel free to contact JEFFREY.FUKUDA@medicaid.ohio.gov or Mark.Graves@medicaid.ohio.gov if you have questions or concerns.