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News and Information exclusively for members of OHCA - please do not forward to non-members

November 6, 2020

Top Stories

OHCA HCH Hot Topics Call

Erin Begin

On Wednesday, November 11, 2020, at 1:00 p.m., OHCA will host our monthly Hot Topics call for home care and hospice members. On the call, OHCA staff members will provide updates on the most important issues of the day, such as the hospice final payment rule, provider relief fund options and review choice demonstration.  Hot Topics calls usually are held on the second Wednesday of every month and are free to OHCA members. There is no need to register, and we encourage you to have as many people listen in as you wish.  We understand and respect the value of your time, so we try to keep the calls to less than one hour.  This month, we will be discussing how the COVID-19 vaccination distribution plans, home health final payment rule, access to COVID-19 testing, updates from the quarterly ODH meeting and much more.

 

To join the video conference:

1. Join using Zoom Meeting link

2. OR Use your telephone to dial the conference call number: (312) 626-6799. When prompted, enter the conference code: 841 7966 9810, password 2020


POC Tests and Machines Available for Home Health and Hospice
Diane Dietz
McKesson informed OHCA that they are taking orders for BD Veritor point-of-care (POC) COVID-19 testing machines along with test kits. This opportunity may be particularly beneficial to home care and hospice providers who previously did not have access to this rapid testing technology.


Only organizations with a Clinical Laboratory Improvement Amendments (CLIA) Certificate of Waiver are permitted to run rapid COVID-19 diagnostic tests through a POC machine. The Department of Health’s CLIA Laboratory Certification webpage provides information on how to obtain a CLIA Certificate of Waiver. Please note that according to McKesson, BD is drop-shipping their Veritor machines directly. Once ordered through McKesson, fulfillment is running approximately 4-6 weeks, although some orders have shipped faster. To learn more, please contact Jeff Mazer at Jeff.Mazer@McKesson.com.

Reimbursement 

Provider Relief Fund (PRF) Phase 3 General Distribution Application Due Tonight
Erin Begin
Before 11:59 p.m. tonight, applications for Phase 3 must be submitted to the Department of Health and Human Services (HHS). A broad range of health care providers are eligible for this phase, which is intended to fill any gaps between previous PRF distributions and lost revenue/increased cost incurred in the first two quarters of 2020. According to HHS officials on a call this afternoon, an applicant must submit their Tax Identification Number (TIN) for validation by tomorrow, and they will have until November 27 to complete the application. A provider who still has an application pending for Phase 2 may apply for revalidation of their TIN for Phase 3.


Additional Guidance on Late RAP Submission Penalty
Erin Begin
This week, the Centers for Medicare and Medicaid Services (CMS) issued a revisions to the Medicare Learning Network (MLN) article MM11855, Penalty for Delayed Request for Anticipated Payment (RAP) Submission Implementation
.  The revision involved remittance advice responses for RAP penalties initiated due to submitted the RAP after the 5 day deadline and Low Utilization Payment Adjustment (LUPA) claims which result in no payment for visits made prior to the RAP submission.  HHAs should note that MACs will:

  • Report the following remittance advice messages for the late submission payment reduction in the Claim Level CAS segment (loop 2100) on Home Health Claims on the 835 ERA
    • Group Code: CO
    • Claim Adjustment Reason Code (CARC): 95 ("Plan procedures not followed")
  • Report the following remittance advice messages for the late submission payment reduction in the Claim Level CAS segment (Loop 2320) on Home Health Claims to the 837I COB
    • Group Code: CO
    • CARC: 95 ("Plan procedures not followed") 

CMS Home Health and Hospice Open Door Forum Updates
Edited from NAHC Report
The Centers for Medicare & Medicaid Services (CMS) held a Home Health, Hospice and Durable Medical Equipment (DME) Open Door Forum (ODF) on November 4 where CMS reviewed information and resources it has recently released.  A summary for home health is below:

  • High level review of the Home Health Final Payment Rule.  Please see last week’s news bites for the OHCA summary
  • Review of the no-pay RAP penalty instructions released.  Additional details are provided in the article above.
  • New Home Health Quality Reporting Program materials released:
  • The October 2020 refresh of home health data that appears on Compare includes a measure change reflecting finalized rule proposals, specifically a new skin integrity measure reported for the first time and the previous pressure ulcer measure removed. As previously reported, CMS will not refresh data on Care Compare in 2021 due to the excepted quality reporting during the first two calendar quarters of 2020.  This means there will not be any preview reports provided during 2021.v
  • CMS provided notification to home health agencies that were determined to be out of compliance with the HHQRP  requirements for CY2019, which will affect their CY2021 Annual Payment Update (APU). Non-compliance notifications were distributed by the Medicare Administrative Contractors (MACs) and were in HHA’s My Reports folders in iQIES on October 7, 2020. Home Health Agencies that received  a letter of non-compliance may submit a request for reconsideration to CMS via email no later than 11:59 pm, November 6, 2020. Instructions for submitting a reconsideration request are found in the non-compliance notification letter and on the Home Health Quality Reporting Reconsideration and Exception & Extension Web Page.
  • The next Home Health Care CAHPS (HHCAHPS) Survey Vendor Update Webinar training session will take place on January 29, 2021 from Noon – 2:00 PM Eastern. Online registration to attend the training session will be available on December 1, 2020. 

Home Infusion Therapy Supplier Enrollment Information Available
Erin Begin
Recently, CMS updated the enrollment policies for home infusion therapy (HIT) suppliers, amending the enrollment instructions in Chapter 10 of the Medicare Program Integrity Manual.  The Medicare home infusion therapy services benefit covers the professional services, including nursing services, furnished in accordance with the plan of care, patient training and education (not otherwise covered under the durable medical equipment benefit), remote monitoring, and monitoring services for the provision of home infusion therapy and home infusion drugs furnished by a qualified home infusion therapy supplier.  Providers wanting to enroll as HIT suppliers can do so beginning on or after November 1, 2020.  This involves completion and submission of the CMS Form 855-B.  Providers must also be accredited by an approved accrediting organization for HIT services prior to being approved as a Medicare Part B HIT supplier.  Accreditation must be received in order for the CMS Form 855B application to be processed.  Please see the full Change Request for additional details.


Regulatory


Updates from ODH for Home Health and Hospice
Erin Begin
Earlier this week, OHCA participated in a non-long term care provider association meeting with the Department of Health (ODH). We sent several questions in advance to be addressed during the meeting. Please find below a summary of updates and comments:

  • Survey activity: Currently, ODH still is conducting only complaint surveys and initial certification surveys for non-long term care providers, with the exception of maternity units. ODH does not have a date when they expect regular survey activity will resume. ODH personnel did clarify that once surveys resume, ODH will prioritize providers whose dates for recertification lapsed. Providers are not subject to penalty at this time, as the state reserves the right to suspend regular survey activity during the Public Health Emergency (PHE). Additionally, ODH staff stated that there have not been any citation trends on the complaint surveys, but they issued several individual citations. ODH provided examples of screening practices for staff, lack of eye protection in COVID-19-positive patient rooms, and lack of COVID-19 policies.
  • Accrediting Organizations (AOs) and virtual surveys: In previous meetings, ODH informed OHCA that Centers for Medicare and Medicaid Services (CMS) does not accept the virtual surveys conducted by the Joint Commission. ODH subsequently reached out to CMS, who explained that they intend to release a memo to the AOs providing clarification and guidance on resumption of recertification surveys that will address this question. We will advise members once that information is available.
  • Ohio vaccination program: ODH staff were unable to provide an update on prioritization of home health and hospice workers in the Ohio Vaccination Distribution Plan at this time.
  • Line-level Clinical Laboratory Improvement Amendments (CLIA) reporting: ODH's CLIA program will conduct random inspections of providers who perform CLIA-waived tests for compliance, including line-level reporting, in the near future. ODH is not aware of any compliance issue associated with home health or hospice specifically.
  • Alternative testing options: OHCA requested an update on availability of point-of-care antigen tests for home health and hospice staff. While Abbott BinaxNOW tests are not available for purchase, ODH’s Shannon Richey said they have seen several applications come through for other approved CLIA-waived options. This would be test options in addition to the BD Veritor machine mentioned in the article above.  She agreed to share the list with us. As soon as we receive the information, we will pass that on to home health and hospice members.
  • Palliative Care Interdisciplinary Council: Because of the PHE, the council temporarily suspended its work and meetings. Bimonthly meetings are set to resume in January 2021.

FDA Issues Letter on Antigen Testing
Diane Dietz
The Food and Drug Administration (FDA) released a letter to laboratories and health care providers with interesting information about false positive results from antigen COVID-19 tests, for example point-of-care testing machines like the BD Veritor and Abbott BinaxNOW cards. The FDA explains that false positive results can arise from improper testing techniques and conditions. Any member using antigen tests should review these reasons for false positives to ensure that their testing process affords the best opportunity for accurate results. The FDA letter also explains the statistical probabilities of false positives in surveillance testing, which vary inversely with the prevalence of COVID-19 in the general population. For instance, if prevalence is low at 0.1%, 96% of positive antigen test results are likely to be false. According to the Centers for Disease Control and Prevention, positive antigen test results in a surveillance testing regimen should be confirmed with a PCR test.


McCloud Becomes Director of Health
Mandy Smith
At his press conference yesterday, Governor Mike DeWine announced that he appointed Stephanie McCloud, previously Administrator of the Bureau of Workers' Compensation, as Director of Health. The Governor also made other personnel moves in the department. From the official release by the Governor's Office's: 


Chief Medical Officer Dr. Bruce Vanderhoff: Dr. Vanderhoff previously served for more than a decade as a Senior Vice President and as the Chief Medical Officer at OhioHealth. He has years of experience leading large teams in successfully dealing with important healthcare issues in Ohio and prepared OhioHealth to deal with the threat of Ebola and the H1N1 flu pandemic. 

 

Director Stephanie McCloud: Director McCloud previously served as Governor DeWine's administrator of the Ohio Bureau of Workers' Compensation, managing an agency of 1,800 colleagues and over $28 billion in assets. She has considerable experience in the area of mental health and addiction treatment which is a priority in Ohio's health improvement plan. 


Senior Deputy Lance Himes: Himes had previously served as the interim director of ODH where he has played an integral role in running and managing many aspects of the pandemic response operation. He will lead the coordination of the state’s vaccine distribution plan and will continue to work directly with Ohio’s local health commissioners.


Chief of Staff Kathleen Madden: Madden had previously served as Assistant Director at the Ohio Office of Budget and Management and will now play a key role in keeping ODH's pandemic and non-pandemic programs and operations on track. She will work to prioritize and resolve critical issues, provide oversight and guidance to ODH staff, and ensure that ODH funds are spent responsibly and strategically.


OSHA Issues New Long-Term Care Respiratory Protection Guidance
Diane Dietz
Late last week, the Occupational Safety and Health Administration (OSHA) released a new document entitled, "Respiratory Protection Guidance for the Employers of Those Working in Nursing Homes, Assisted Living, and Other Long-Term Care Facilities During the COVID-19 Pandemic." This is of particular interest to home health and hospice workers who care for patients in these facilities.  In the guidance, OSHA provides a hierarchy of items that can be used to cover an employee's mouth and nose, starting at the bottom with cloth face coverings and moving on to facemasks. OSHA characterizes both of these as beneficial for source control, but not as personal protective equipment. Surprisingly, OSHA equates KN95s with facemasks: "An example of this type of product would be a KN95 respirator with ear loops instead of head straps and that has not undergone rigorous fit testing to demonstrate a proper fit/effective seal to the wearer’s face." Next in the hierarchy are true surgical masks, which protect against splashes and sprays but do not provide respiratory protection, and at the top, N95 or higher filtering facepiece respirators (FFRs).


After the hierarchy, OSHA discusses in some detail the required respiratory protection program. Here are a couple of noteworthy provisions:

  • "During times like the present pandemic, when there are increased demands on the supply chain for N95 FFRs, consider alternatives to N95 FFRs, including other FFRs (e.g., P100s, N99s), reusable elastomeric (rubber) respirators, and powered air purifying respirators (PAPRs)." OSHA goes on to say that while initially more expensive, the latter two types of respirators may save providers money because they are reusable.
  • "Note that while N95 FFRs are meant to be discarded after each use, CDC has developed contingency and crisis strategies, including reuse and decontamination of N95 FFRs, to help healthcare facilities conserve their supplies in the face of shortages." This section of the guidance specifically links to one of the Centers for Disease Control and Prevention (CDC) guidelines that in crisis capacity for N95s allows use of respirators "that are similar to NIOSH-approved respirators but are not NIOSH approved and are approved according to standards used in other countries. The performance of some internationally approved respirators was evaluated by NIOSH and the results can be found here." The referenced list includes a number of KN95s.

This provision, which seems to condone the practice of substituting KN95s for N95s when a facility is in crisis capacity, appears to conflict with the earlier provision equating KN95s with simple facemasks for source control only. OHCA will continue to investigate how this guidance affects the practice of wearing KN95s when N95s are not available. We will provide more information as we learn it, but want members to be aware that the new OSHA guidance is out.


CMS Resource: How to Prepare for the COVID-19 Vaccine
From Medicare Learning Network Connects
Get ready to administer the COVID-19 vaccine when it’s available. Read the enrollment section of our COVID-19 provider toolkit to see if you need to take action now:

  • Many Medicare-enrolled providers don’t have to take any action until a vaccine is available – make sure your provider-type enrollment is all set
  • Some Medicare-enrolled providers must also separately enroll as a mass immunizer to administer and bill for COVID-19 vaccines when they’re available – find out if you must also enroll as a mass immunizer
  • If you’re not a Medicare-enrolled provider, you must enroll as a mass immunizer or other Medicare provider type that can bill for administering vaccines

Enrolling over the phone a mass immunizer is easy and quick — call your MAC-specific enrollment hotline (PDF) and give your valid legal business name, national provider identifier, tax identification number, practice location, and state license, if applicable.

Other News

Ohio Daily Case Count Nearly 5,000, LTC Cases Skyrocket

Mandy Smith

The number of positive COVID-19 test results ballooned to 4,961 yesterday, 732 (17%) more than the previous daily record. A record number of 2,075 people are currently hospitalized with the disease, with 541 in intensive care, also an all-time high. We are beginning to hear of hospitals reaching capacity. On the newly-released Ohio Public Health Advisory System map, 56 counties are at the red level, 13 more than last week. Most of the counties remaining orange and yellow are sparsely-populated rural counties.

 

Previously, on Wednesday, the state dashboard showed 1,788 new resident cases in SNFs, assisted living communities, and ICFs/IID and 1,228 cases among staff. The total of more than 3,000 long-term care cases in one week easily surpasses previous levels. The explosion of weekly cases in long-term care from 1,097 as recently as September 30 to 3,016 this week thankfully has not been accompanied by an increase in COVID-19-related deaths.

 

ACHC Offers Distinction in Telehealth Accreditation

Erin Begin
Accreditation Commission for Health Care (ACHC) announced this week the launch of its Distinction in Telehealth accreditation program.  The ACHC
Distinction in Telehealth recognizes the value telehealth offers to improving patient care delivery, reducing hospital readmissions, and lowering costs for providers and patients.  It is available for organizations offering services in home health, hospice and private duty. To earn a Distinction in Telehealth, a provider must be accredited by ACHC.

 

Ohio Elections: GOP Strengthens Hold on General Assembly
Pete Van Runkle

While the national election results remain in doubt, Ohio's legislative races are final, save one Senate seat. Reflecting President Donald Trump's relatively easy, 8-point win here, Republicans consolidated their already-massive majorities in the Senate and House of Representatives. As was the case with the Presidential and Ohio Congressional races, the legislative results confounded the predictions, which had Republicans losing seats in both the House and Senate.


Senate Republicans either gained one seat or maintained their 24-9 advantage, depending on a recount in the 16th District, where incumbent Republican Stephanie Kunze finished 41 votes ahead of her challenger, Crystal Lett. The Republican pickup was in the 32nd District, where Sandra O'Brien ousted the incumbent Democrat, Sean O'Brien.


In the House, Republicans achieved a net gain of 3 seats, running their majority to 64-35. While incumbent Republican Dave Greenspan lost to Monique Smith in the 16th District, Mike Loychik (63rd District) and Gail Paviglia (75th District) defeated incumbent Democrats Gil Blair and Randi Clites, while Republicans Ron Ferguson and Sarah Fowler picked up the vacant 96th and 99th Districts, both formerly in Democratic hands.


The Supreme Court races, featuring two Republican justices running for re-election, split. Democrat Jennifer Brunner defeated incumbent Judi French, while the other incumbent Republican, Sharon Kennedy, dispatched challenger John O'Donnell.


Association News/Services

Free Recruiting Website
As part of a national platform, OHCA developed Ohio Care For The Aging as an informational resource that offers education on a wide range of career opportunities available in the long-term services and supports profession. The site will inspire those who are looking for a new career opportunity to become part of this rapidly growing and gratifying field. As a complimentary member benefit, OHCA members who set up accounts and post their employment opportunities will have job seekers directed to them. Ohio Care for the Aging is an OHCA initiative to provide career information and workforce development and to recruit compassionate and dedicated people to the mission of serving the elderly and disabled in long-term and post-acute care professions in Ohio. The national website carefortheaging.org directs job seekers to the Ohio portal.

Free Job Posting Available to Members
Members may post openings in the Job Opportunities section of the OHCA website for 30 days at no cost. To post an opening, go to the Long Term Care Careers page at www.ohca.org, log in, and post the job through your account. You will need to be logged into the site with your user name and password before you attempt to post a position.


Home Care News Bites
OHCA's Home Care News Bites is distributed electronically each week to OHCA home care members. To be added to or deleted from the distribution list, please email Debbie Jamieson.