March 11, 2020
CMS home health guidance. Late last night, the Centers for Medicare and Medicaid Services (CMS) issued specific COVID-19 guidance for home home health agencies. Quality, Safety, and Oversight (QSO) Letter 20-18-HHA builds on previous Centers for Disease Control and Prevention (CDC) guidelines for care at home. In a question-and-answer format similar to the previous day's hospice guidance, the home health guidelines have some similarities to the portions of the hospice recommendations that deal with home care but are more detailed. The home health guidance deals with such issues as use of personal protective equipment (PPE) and supplies, screening patients and staff, and when patients can be cared for at home or should be hospitalized. QSO 20-18 includes step-by-step instructions for donning and doffing PPE.
Guidance for ID/DD providers. To date, neither CMS nor CDC have issued COVID-19 guidelines specific to ID/DD providers. Some of the federal recommendations for home care and for SNFs may be applicable, but should be adjusted to reflect the population served, which of course varies in terms of medical complexity and community involvement. The Department of Developmental Disabilities (DODD) convened a stakeholder call on COVID-19 this morning and agreed to requests to provide guidance for Ohio ID/DD providers. DODD also outlined the precautions they are taking at developmental centers, which are considerably more stringent than we believe is appropriate for non-state-operated settings. We hope to receive the department's guidance soon.
CMS relaxes PPE recommendations. Acknowledging the nationwide shortage of N95 respirators, CMS issued QSO 20-17-ALL, which gives alternatives for providers who cannot obtain respirators. The guidance allows substituting facemasks for respirators and recognizes a Food and Drug Administration decision allowing respirators other than N95s with current dates. The QSO also provides exceptions to the need to use gowns and airborne infection isolation rooms when they are not available.
Governor DeWine steps in. After issuing a minimimal pronouncement yesterday following a call with SNF and assisted living representative ("we are recommending that nursing homes screen all visitors, including volunteers and vendors, for symptoms of contagious illnesses"), Governor Mike DeWine and Health Director Dr. Amy Acton held a press conference this afternoon that went much farther. The Governor said Director Acton would issue an order - which we have not yet received - requiring SNFs and ALs to limit visitors to one per resident per day, to take temperatures of anyone who enters the building, to close off but one entrance, and to maintain logs of entrants. As stated, these requirements would conflict with Monday's CMS and AHCA/NCAL guidelines that providers across the state are implementing. Depending on what is in the written order, OHCA will press the Administration to remove the conflicts. In the meantime, members should continue to follow the CMS and AHCA/NCAL guidance.
Medicare Advantage. CMS released a notice to Medicare Advantage plans giving them permission - not a mandate - to waive certain requirements for COVID-19-related services.