October 1, 2020
SNF Testing Notices. In
two separate Enhanced Information Dissemination and Collection System
(EDIC) notices, the state formally announced the batch upload process
for the Department of Health (ODH) laboratory portal and the SNF testing
schedule for the next two weeks. The batch upload process is intended
to keep providers from having to reenter data for each round of testing.
Please review the instructions, which have screen shots showing how to use the process, and the data dictionary, which details the information that needs to be entered into the batch upload. The schedule
for October 5-18 is the first to reflect the new state-supported
testing process that only covers certain buildings. The schedule was
accompanied by the following text:
IMPORTANT NOTES – PLEASE READ!!
- PLEASE CAREFULLY REVIEW THE SCHEDULE FOR DAY OF THE WEEK AND LAB CHANGES
-
The changes were made to ensure state support could be available
for routine and outbreak testing, as described in the attached webinar slides.
-
A few nursing homes switched from Quest to a state lab (Battelle,
Dayton Children's, OSU, ODH, UC Health). Additional information will be
sent to these facilities.
-
A NEW survey will be created and circulated via EIDC – this
survey will be used going forward to update their opt in/out status,
report the need for outbreak testing, and report changes in staff and
resident test kit needs.
- Additional updates will be made next week to accommodate future outbreak testing needs.
New OPHAS Map Shows More Red. Today being Thursday, the state released a new Ohio Public Health Advisory System (OPHAS) map. Four new counties (Clermont, Hamilton, Muskingum, and Richland) turned
red, bringing the total to 11, while Delaware and Stark Counties went
from red to orange. The main significance for SNFs is that Clermont and
Hamilton Counties are green in the federal table,
so the red Ohio designation means they are mismatch counties that now
must test weekly instead of monthly. The OPHAS map is not mandatory for
visitation, but providers are required to consider whether to continue
to allow visits when the color level increases.
PRF Phase 3 Portal Opens Monday. The Department of Health and Human Services (HHS) today issued a formal announcement
of the Phase 3 General Distribution from the Provider Relief Fund
(PRF). The purpose of Phase 3, which will pay out $20 billion of the
approximately $50 billion left in the PRF, is to address remaining
COVID-19-related revenue losses and increased expenses that were not
covered by previous PRF distributions. Providers who received previous
General Distributions or who opened in the first quarter of 2020 are
eligible for consideration under Phase 3, but they must submit
applications between this coming Monday, October 5, and November 6.
Eligible providers include Medicare (e.g., home health agencies,
hospices, SNFs) and Medicaid (e.g., ICFs/IID, Medicaid waiver) providers
as well as private-pay assisted living communities. The relatively
short window for applying is because the payments to individual
providers will be determined in part by how many apply. The details are
not available yet, but HHS gave a general description of the data
applicants must submit:
- A provider’s change in operating revenues from patient care
- A provider’s change in operating expenses from patient care, including expenses incurred related to coronavirus
- Payments already received through prior Provider Relief Fund distributions.
The announcement does not specify the time period for data reporting.
Livanta Releases Waiver Application. In
yesterday’s COVID-19
Update, we discussed the availability of a waiver that would enable
approved providers to continue submitting faxed or hard copy medical records to Livanta after
October 1, 2020. Today, Livanta released the waiver application.
A Livanta representative stated that they intend to process the waivers
very quickly. To qualify, a provider
must show it lacks an electronic medical record
system capable of securely transmitting electronic records to Livanta
and must sign a memorandum of agreement (MOA) with Livanta if required
to do so. The waivers will be in effect through December 31, 2020, and
are intended to give providers more time to secure a direct secure
messaging
application. Records received through fax or hard copy from providers
who
do not have an approved waiver will not be accepted. Another option to
meet the new requirement is to use the Livanta e-LiFT
portal, which is available now. For more information on
the requirements, please see links below or contact Erin Begin.
COVID-19 Impact on ICF/IID Cost Reporting. Today, the Department of Developmental Disabilities (DODD) shared Medicaid Advisory Letter (MAL) No. 647, which
addresses provider questions on how to account for COVID-19-related
expenses and other revenue/stimulus sources. MAL 647 is follow-up
guidance to two other Medicaid Advisory Letters (MAL 644 and MAL 646) released in early August.
President Trump Signs Continuing Resolution with Advanced/Accelerated Payment Extension. President Donald Trump today signed HR 8337,
a continuing resolution to fund the federal government through December
11, after it passed the Senate last night. The legislation contains
repayment relief for Medicare providers who received advanced and
accelerated payments earlier this year. Most importantly, it extends
both the start date and the end date for Medicare to recoup the advanced
money, providing significant cash flow relief. See AHCA's summary for additional detail.
Update on CLIA Line-Level Reporting: Which Direction? OHCA
today discussed with ODH their efforts to move all Ohio laboratories to
electronic reporting of COVID-19 line-level data and how this activity
relates to the recent announcement by the National Healthcare Safety
Network (NHSN) that they will create a new pathway SNFs may use to
comply with the upcoming line-level reporting requirements for their
point-of-care antigen tests. ODH is reviewing a draft of the NHSN
pathway while continuing final testing of the comma-separated value
(CSV) file upload that Ohio labs alternatively can use to comply with
the reporting requirements.
Facilities
with Clinical Laboratory Improvement Amendments (CLIA) Certificates of
Waiver will need to choose from the following two options to report the
required data:
- Create a secure file transfer protocol (FTP) connection with ODH and begin populating the CSV template according to ODH's formatting instructions.
- Use the NHSN platform when it comes on line, which NHSN expects to be October 15.
We
learned from ODH that the NHSN platform unfortunately will not allow a
data upload, which means providers must submit all required data
elements such as name, address, sex, race, age, etc., individually for
each COVID-19 test using an antigen point-of-care unit or BinaxNOW
card. According to ODH, however, NHSN intends to make many of the data
fields auto-populate after the data are entered the first time, which
would reduce data entry for each test run.
The
state option will continue to require submitting the line-level data
electronically to ODH via a CSV file, although the file can be
pre-populated with most of the required data fields, then uploaded daily
to ODH for tests run that day. We also learned that ODH is exploring
another option for electronic data submission that would eliminate the
challenges of establishing a secure FTP connection. ODH is not prepared
to announce this new option today, but they hope to unveil it very soon.
At this point, we recommend all members contact
NHSN immediately to upgrade their Secure Access Management Service
(SAMS) access from Level 1 to Level 3 so they have the ability to use
the new NHSN lab reporting pathway if they choose. Members can learn about increasing their SAMS access by clicking here and can email nhsn@cdc.gov with the subject line “Enhancing Data Security” to begin the upgrade process. In
the meantime, we encourage members to evaluate how best to comply with
the line-level reporting requirement, which apparently will involve
either a CSV file upload to ODH or entering data on each antigen test
via the NHSN pathway. We will continue to provide more information as it
becomes available.