Elevating the Post-Acute and
Long Term Care Profession

May 29, 2020


Mandatory testing webinar Tuesday. According to a notice published on the Health Department's (ODH's) Enhanced Information Dissemination and Collection system and shared with the associations, the state plans to hold its introductory webinar for SNFs on the testing program on Tuesday. All Ohio SNFs are invited. We believe the webinar will be in the morning, but no time has been announced. The state does not plan to do any testing Monday, then will start a soft launch with the webinar. Any center selected for testing thereafter will be notified in advance. The pilot phase ended today, with employees at an additional 6 centers tested. We heard reports from two pilot buildings that the process went smoothly. We have not received any written guidance on the testing program from ODH or the Department of Medicaid (ODM).

CMS expands outpatient telehealth therapy billing to SNFs, HHAs. In updated COVID-19 frequently asked questions (FAQs) on Medicare fee-for-service (FFS) billing, the Centers for Medicare and Medicaid Services (CMS) clarified several points relating to home health agency (HHA) and SNF providers billing outpatient therapy telehealth visits.

  • Outpatient therapy services furnished via telehealth and separately paid under Part B may be billed by SNFs on a UB-04 (22X and 23X Type of Bill) and HHAs (34X type of bill) using the -95 modifier.
  • AHCA prepared an additional FAQ document giving to their interpretation of this change as it relates to consolidated billing.
  • For HHA therapy services under a home health plan of care, services are bundled into the Part A payment to the HHA, and those services must be billed under consolidated billing rules. Per NAHC Regulatory Director Mary Carr, this does not impact limitations on reporting telehealth therapy visits on claims for skilled Part A home health billing periods, as these visits still do not count toward Low-Utilization Payment Adjustment (LUPA) thresholds.

Why the hold-up on communication technology grants? Following up on member questions, we learned that ODM has not approved any of the applications for funding to purchase communication technology. Under a federal directive, ODM is offering grants to SNFs of up to $3,000, funded by the Residents Protection Fund, which consists of receipts from civil money penalties on SNFs. OHCA inquired multiple times about the status of the grants, and finally ODM's Julie Davis reported that the agency determined the expenditures require approval by the Controlling Board, a legislative body that has authority to allow unbudgeted state spending. ODM's request for the technology grants is on the board's agenda for Monday, so hopefully it will be approved and the funding will flow shortly thereafter.

ODM extends deadline for alternate EVV certification to September 1, 2020. Today, OHCA received notification that ODM extended the deadline for alternate electronic visit verification (EVV) systems to achieve certification to September 1, 2020. This change came in response to feedback, including a joint letter from the Ohio Council for Home Care and Hospice, OHCA, and LeadingAge Ohio. ODM encourages providers to complete the process as quickly as possible. 

In their letter, they state:

On December 23, 2019, we notified you that all alternate system vendor–provider combinations must complete the alternate system certification process by June 30, 2020. As we explained then, both the alternate system demonstration requirement and the Sandata process validating the transmission of EVV data to the aggregator must be completed successfully. More recently, you may have received a letter, phone call and email reminding you of these deadlines. 

Since our most recent communication, we have received feedback that the COVID pandemic has presented challenges to providers and vendors as they work to meet the certification requirements. As a result, we are extending the time to complete the certification process until September 1, 2020. Providers who have not completed the certification process by September 1, 2020 may be required to transition to the Sandata system until their alternative system is fully certified.

PPE assistance for HCBS waiver providers. We learned today from the Ohio Association of Areawide Agencies on Aging that the area agencies are receiving skids of personal protective equipment (PPE), primarily masks, that is intended for waiver providers (e.g., PASSPORT, Assisted Living). If you are an aging waiver provider and need PPE, you should reach out to your local agency to see if they have any available.

 

With Support from OHCA Champion Partners