March 13, 2020
Governor orders school closure. Yesterday, Governor Mike DeWine announced at his daily press conference that he is ordering all schools in Ohio to close for three weeks, starting after school on Monday, March 16. This action will have significant consequences for health care staff availability during that period. OHCA is looking for measures to help members cope with this development.
OHCA event cancellation. OHCA canceled all in-person events and meetings for the next 30 days. We are working to utilize remote technology or to reschedule for later in the year, as we can. We also are working with the Board of Executives of Long-Term Services and Supports and other licensing agencies to seek relief on continuing education requirements. We will make a decision about the OHCA convention by the end of this month, although as of now, yesterday's order by Director of Health Dr. Amy Acton prohibiting gatherings of more than 100 takes that decision out of our hands.
Visitation order update. Also at yesterday afternoon's press conference, the Governor said Director Acton's Wednesday order on visitation in SNFs and residential care facilities will be modified. Beginning early yesterday morning, OHCA informed state officials that the provision allowing one visit per resident per day conflicts with more restrictive federal guidance that providers in Ohio already had implemented and breaks down protections for residents. Governor DeWine acknowledged those concerns when he discussed changing the order to restrict visitation further. OHCA recommends members continue to enforce their more restrictive visitation policies pending revision of the order. In addition, we understand the Health Department (ODH) last night published a clarification letter on the Enhanced Information Dissemination and Collection (EIDC) system.
Hospice in SNFs. We heard from hospice members that in some cases, SNFs denied entry to hospice personnel serving patients in the SNF based on the ODH order. This is erroneous. As contracted health care providers, hospice staff are defined as "absolutely necessary" personnel, not visitors, under the order. Moreover, Centers for Medicare and Medicaid Services (CMS) hospice guidelines for COVID-19 clearly state that hospice workers should be given entry (see page 6).
OHCA all-provider call. Yesterday afternoon, OHCA held a conference call open to all Ohio long-term services and supports providers to explain the current COVID-19 guidelines for assisted living, home care, hospice, ID/DD services, and skilled nursing. The call reached capacity, and some people were unable to participate. A recording of the call is available here, with the caveat that it reflects a specific moment in time, as guidelines are changing rapidly.
DODD direction. Of all long-term services and supports providers, those serving people with intellectual and developmental disabilities (ID/DD) have the least specific guidance on COVID-19. That should change in the next day or so. We understand from ANCOR that CMS is developing recommendations for ICFs/IID. The Department of Developmental Disabilities also is developing Ohio-specific guidance. Yesterday Director Jeff Davis published a letter on COVID-19. In the meantime, OHCA recommends that members serving people with ID/DD familiarize themselves with existing CMS guidance for SNFs and for home health agencies, along with NCAL's suggestions for assisted living. While not specifically applicable, these guidelines give a sense of precautions that ID/DD providers should institute.