March 16, 2020
Today Governor Mike DeWine added polling places, gyms, bowling alleys, movie theaters, and others to restaurants and bars (from yesterday) on the ist of locations closed. Voting will be done by mail through June 2. The Governor also changed the ban on mass gatherings from 100 to 50 people based on yesterday's federal direction, but today President Donald Trump referred to 10 people and urged everyone over 65 to stay home altogether.
Surveys. Today the Health Department (ODH) took unilateral action to halt all recertification surveys. It happened mid-survey, as a number of members reported surveyors appeared this morning, only to leave shortly before noon. ODH explained that they feel CMS soon will suspend recertification surveys, so they decided to cancel them now. We believe ODH now only will do surveys for any provider type for serious complaints.
ODH on hospice in SNFs, RCF recommendations. Rebecca Sandholdt, ODH Survey and Certification Chief, penned a letter late this afternoon that provides direction on two points relating to hospice patients in SNFs. First, Ms. Sandholdt reiterated that hospice personnel should be given access to a SNF to care for their patients and added that they may need to visit multiple times a day. Second, Ms. Sandholdt addressed an issue that SNFs are handling inconsistently across the state: what is considered end of life to allow family visits. She wrote that all hospice patients are considered to be at the end of life, not just those who face imminent death.
Also in the letter, Ms. Sandholdt suggested that assisted living communities (residential care facilities) look to Centers for Medicare and Medicaid Services (CMS) guidelines for direction in dealing with the COVID-19 threat. She emphasized screening all entrants and noted that ODH is awaiting further guidance from CMS on surveys.
Personal protective equipment (PPE). Please utilize this week's ODH Survey Monkey to report PPE shortages. If you need immediate assistance, ODH's advice is to contact the Regional Coordinator for your region. You may find the contact information at this link (go to the Find My Healthcare Coalition tab).
Communal dining. Dr. David Gifford from AHCA reported that CMS informally approved guidance for implementing the ban on communal dining originating from the Indiana Health Care Association. The guidance provides tips on complying with the intent of the ban without serving everyone in their rooms.
Outings. We receive a number of questions from members about families taking residents out of the buildings for outings, potentially as a way of getting around the state and federal visitation restrictions. OHCA's view is that residents should not leave their home, whether it is a facility or their own residence, unless it is medically essential. Although there is no rule that requires it, clearly that is the intent behind such things as the President's recommendations today.
Revised letter to Governor. OHCA, with LeadingAge Ohio co-signing, sent a second, revised letter to Governor DeWine asking for the state's assistance in helping long-term services and supports providers deal with the challenges of providing care during the current emergency.
ICF/IID guidance from DODD. Late last night, the Department of Developmental Disabilities released COVID-19 guidelines for ICFs/IID. They contain a considerable amount of direction on infection control issues and also some significant regulatory flexibility. We appreciate that DODD accepted OHCA's input on the guidelines and recommend all ICF providers review them carefully.
DODD also postponed the National Core Indicators survey at least through April 10.
Three-day stay waiver. For more explanation of the waiver, please see Mike Cheek's (AHCA) notes on the subject as well as today's Medicare Learning Network release, which includes links to frequently asked questions documents on emergency waivers generally, not specific to this particular waiver. AHCA is seeking clarification from CMS whether the spell of illness provisions in the waiver allow a person exhausts their 100-day benefit period to receive a second 100 days.
Nursing delegation - possible staffing assist? Assisted living communities and SNFs may be able to gain staffing flexibility by utilizing nursing delegation. Please see this OHCA paper on the topic. See also these documents on nursing practice, RN/LPN decision-making, and RN/LPN frequently asked questions.