Elevating the Post-Acute and
Long Term Care Profession

May 21, 2020


Yes, you heard correctly: state to roll out mandatory testing in SNFs. In a video conference this evening, State Medicaid Director Maureen Corcoran explained to stakeholders and agency leaders that per the direction of Governor Mike DeWine, the state will begin mandatory COVID-19 testing in SNFs early next week. The National Guard will take the swabs and transport the samples to labs. The program will focus first on the roughly 350 SNFs that have had COVID-19 positives, beginning with those most severely affected and centers that volunteer to participate.

The testing will be mandatory for staff (no opt out) to identify asymptomatic positive staff members who could infect patients and other staff. Patients will be subject to cohort testing, under which only the patients most likely to have been exposed to people positive for COVID-19 will be tested. Ohio explictly is not following the Centers for Medicare and Medicaid Services (CMS) recommendation to conduct weekly testing. Director Corcoran said there likely will be some schedule for repeated testing.

The state is looking at how it will pay the cost of tests that are not covered by insurance. OHCA pointed out that the state must have a plan for mitigating staffing shortages that could result from mass testing of facility employees. Director Corcoran emphasized that the testing program does not apply to assisted living or other congregate settings at this time, but could expand in the future.

SNFs, ICFs/IID to receive CARES Act distributions. SNF operators today received an emailed letter from the Department of Health and Human Services (HHS) indicating they are to get an additional payment from the Provider Relief Fund (PRF) under the Coronavirus Aid, Relief, and Economic Security Act. Although the letter does not specify the timing of the payment, AHCA reports it should arrive tomorrow. The amount stated in the letter ($50,000 plus between $1,800 and $2,000 per bed) is incorrect; the true amount is $50,000 plus $2,500 per bed. A subsequent payment to centers that report COVID-19 cases to the Centers for Disease Control and Prevention (CDC) is expected.

AHCA also reports that ICFs/IID and possibly other Medicaid-only providers will receive a PRF payment tomorrow. Apparently it will be a per-bed payment of an unknown amount. HHS did not send a letter about this payment.

Adult day services, transportation, visitation. This afternoon, the Department of Developmental Disabilities (DODD) reconvened the stakeholder workgroup tasked with discussing these three topics. DODD shared draft updates to previously-released documents, which included adding virtual tours of adult day settings, removing the requirement for floor-to-ceiling walls and allowing dividers at least 6 feet high, and modifying the symptom monitoring log. These changes are still drafts. OHCA will share the updated documents as soon as they are finalized.

DODD’s Debbie Hoffine gave additional guidance on the new Start Toward Emerging Possibilities (STEP) service. She clarified that the STEP service is meant for people who cannot use traditional day service settings. As a result, providers cannot bill for STEP on the same day as adult day or vocational habilitation services.

The group reviewed several proposals for transportation and extensively debated the reasonableness of requiring 6 feet between occupants during transportation. Smaller groups will attempt to find solutions to the transportation concerns.

Finally, the group briefly touched on visitation, with DODD’s Ginnie Whisman presenting a draft best practices document for review. She said the department felt this may be better than the risk/benefit analysis OHCA proposed, but later said another approach is not off the table. Ms. Whisman also commented that DODD believes visits by family, friends, and guardians are extremely important to people. The visitation discussion will continue. Until further orders or guidelines are issued, providers should continue to follow the ICF order and waiver guidelines currently in place.

Molina Healthcare skilling of COVID-19 patients. In response to OHCA member concerns about obtaining skilled authorizations for COVID-19-positive residents, we are speaking with the MyCare Ohio plans about their requirements and processes. Today, Molina Healthcare informed OHCA that they identified an increase in these authorization requests in the last two weeks and decided to approve skilled authorizations related to COVID-19 for residents under MyCare Ohio. Molina spent the last week training their Utilization Management staff on this change. They also proactively are reviewing all denials that fall under this category for reconsideration. Providers do not need to resubmit authorization requests at this time. Please note that normal concurrent review process will occur after the initial 14 day period.

UHC, Humana reinstate authorization requirements. United Healthcare (UHC) suspended prior authorization requirements for admissions to post-acute care settings, including skilled nursing facilities and home health, beginning March 24, 2020. This suspension will end May 31, 2020, for all Medicare Advantage, Medicaid, and Individual and Group Market health plans. UHC revised their COVID-19 Prior Authorization Updates page to reflect the confirmed end date. Providers will need to obtain prior authorization under the previous requirements for all admissions starting June 1, 2020.

Likewise, Humana announced it will reinstate authorizations and referrals for Medicare Advantage, Medicaid, and Commercial lines of business, effective for all required services per Humana policy with a date of service on or after May 22, 2020. This return to the standard authorization policy includes authorizations for outpatient services, inpatient services, post-acute transitions of care, and durable medical equipment and applies to participating/in-network and non-participating/out-of-network providers.

Separately, Humana informed providers that it resumed pre-payment and post-payment medical record reviews as of May 15, 2020.

Guidance on COVID-19 swing bed waiver for SNF placement. Yesterday, CMS released guidance on the recent blanket waiver allowing hospitals to ask Medicare to approve swing beds to provide skilled nursing level care as a hospital service for hospitalized patients who don’t need acute care but can’t find nursing home placement during the COVID-19 public health emergency. In addition to filling this need, the waiver allows a SNF to transfer its residents temporarily to a hospital for SNF care in the hospital beds while the SNF bills CMS for the care and pays the hospital under arrangement. This may be done as long as it is not inconsistent with the state’s emergency preparedness or pandemic plan, or as directed by the local or state health department, as a “facility without walls.” There are several other requirements outlined in the guidance.

VA recommendations for Memorial DayFor Memorial Day 2020, each Veteran’s Affairs (VA) National Cemetery will conduct a brief wreath-laying ceremony, accompanied by a moment of silence and the playing of "Taps." However, in keeping with CDC guidelines to limit large gatherings, the ceremonies will not be open to the public. Instead, VA invites you to participate in these ceremonies virtually. Live stream links and videos of Memorial Day 2020 ceremonies at VA National Cemeteries across the country will be posted here as they occur on May 25.

The VA also runs the Veterans Legacy Memorial (VLM) website, the nation’s first digital platform dedicated entirely to the memory of the 3.7 million veterans interred in VA national cemeteries. They invite family, friends, and visitors to leave tributes or comments on veterans' memorial pages.

OSHA revises coronavirus reporting enforcement policy. The Occupational Safety and Health Administration (OSHA) revised its enforcement policy for recording cases of coronavirus, including COVID-19. Under OSHA’s recordkeeping requirements, coronavirus is a recordable illness. Employers are responsible for recording cases of coronavirus if the case:

Under the new policy issued Tuesday, OSHA will enforce the recordkeeping requirements of 29 CFR 1904 for employee coronavirus illnesses for all employers.

 

With Support from OHCA Champion Partners