Final Reminder to Submit ROP Comments (Due Monday)
Pete Van Runkle
The following article is from AHCA.
This is a final reminder to please submit your comment letters on the Centers for Medicare & Medicaid Services (CMS) proposed rule that aims to ease some of the administrative and paperwork burdens of the Requirements of Participation (RoP) issued last month. Please be sure to submit as many comment letters relevant to you before the deadline at 5 pm Eastern on Monday, September 16, 2019. AHCA has developed several template comment letters and resources, including specific letters on the Certified Dietary Manager and Life Safety Code requirements and a summary listing the regulatory areas that CMS has proposed to change. These materials are available for you to download and use on the RoP ahcancalED page here. Instructions on where and how to submit your letters are located below. Thank you for your time and continued support. If you have any questions, please email the AHCA Regulatory team at regulatory@ahca.org.
**Where and How to Submit Your Letters**
- When submitting comments, you need to refer to file code CMS-3347-P.
- CMS will NOT accept comments by fax transmission.
- You may submit comments in any one of the below three ways but only need to use one method: NOTE: AHCA highly recommends submitting comments electronically as letters must be received -NOT postmarked- before the deadline.
1. Electronically. You may submit electronic comments on this regulation to https://bit.ly/33cxW29 by clicking on "Comment Now" in the top right-hand corner of the page. For further instruction on how to submit your comments, view the Tips for Submitting Effective Comments https://www.regulations.gov/docs/Tips_For_Submitting_Effective_Comments.pdf at regulations.gov.
2. By regular mail. You must allow sufficient time for mailed comments to be received before the close of the comment period (NOT postmarked). You can mail written comments to the following address:
Centers for Medicare & Medicaid Services
Attention: CMS-3347-P
P.O. Box 8010
Baltimore, MD 21244-1850.
3. By express or overnight mail. You must allow sufficient time for mailed comments to be received before the close of the comment period (NOT postmarked). You may send written comments to the following address:
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-3347-P
Mail Stop C4-26-05
7500 Security Boulevard
Baltimore, MD 21244-1850
Updated List of Excluded Individuals and Entities (LEIE) Database File
Mandy Smith
From AHCA/NCAL - Long Term Care Leader
The US Department of Health and Human Services, Office of Inspector General (OIG) has released its updated List of Excluded Individuals and Entities (LEIE) database file, which reflects all OIG exclusions and reinstatement actions up to, and including, those taken in August 2019. This new file replaces the updated LEIE database file available for download last month. Individuals and entities that have been reinstated to the federal health care programs are not included in this file.
The updated files are posted on OIG’s website at http://www.oig.hhs.gov/exclusions/exclusions_list.asp, and healthcare providers have an “affirmative duty” to check to ensure that excluded individuals are not working in their facilities or face significant fines.
Instructional videos explaining how to use the online database and the downloadable files are available at http://oig.hhs.gov/exclusions/download.asp.
As a best practice, long term care providers should check the LEIE on a regular basis.
PDPM Questions/Clarification from the CGS Webinar
Mandy Smith
Q. The speaker from CGS told the audience that to transition to PDPM all PPS assessments have to be completed and submitted by 9/30 and PDPM IPAs have to be COMPLETED and SUBMITTED by 10/7. Lots of listeners had a question about this at the end of the call and she confirmed her statement and said that PDPM Q&A on CMS website either has been updated or will be updated shortly.
The last Q& A update on CMS website is dated 8/30, and there is nothing new about the transition. Just the ARD required for PPS no later than 9/30 and for PDPM - no later than 10/7. Nothing about changes in completion/submission timing. Can you clarify for our Ohio members?
A. Per CMS PDPM Team: PDPM does not change the completion and submission requirements for any PPS assessments. Providers still have 14 days from the ARD to complete the assessment and then 14 days from the date of completion to submit the assessment. This applies to both the RUG-IV assessments with an ARD on or before 9/30, as well as any PDPM assessments with an ARD on or after 10/1.
Additional Resources available here.
ODA Satisfaction Surveys – Free Member Webinar
Mandy Smith
Erin Pettegrew with the State LTC Ombudsman reports that they are finalizing the contracts and that ODA will begin the resident satisfaction surveys in the next few weeks. The surveys will be conducted by Vital Research. OHCA is committed to helping facilities achieve the highest resident satisfaction by addressing resident concerns and improving the resident experience. On September 9, 2019 OHCA provided a free member webinar reviewing the satisfaction survey questions, tips for improving resident satisfaction and preparing for the surveys, as well as how to access your facility-specific results. Although the document of the survey questions says 2017, they are the same questions for 2019. At the end of the webinar we reviewed the ODA Quality Improvement Projects for nursing homes. See the webinar posted here.
Managed Care
Administering State of Ohio Employee Benefits
Erin Begin
From the Provider Mutual News Q3 2019 Newsletter
Effective July 1, 2019, Medical Mutual is the new medical plan administrator for State of Ohio employees in the Columbus and Toledo regions. Approximately 60,000 State of Ohio members in these areas are now covered by Medical Mutual, in addition to Medical Mutual’s already existing coverage of State of Ohio members in Northeast Ohio. As Medical Mutual is working to ensure a smooth transition for our new State of Ohio members, we are relying on providers to accept only up-to-date ID cards, pay close attention to prior authorization guidelines, and submit all claims accordingly. State of Ohio members received their ID cards in June 2019. An example of a current Medical Mutual ID card can be reviewed below. To review Medical Mutual’s prior authorization guidelines, visit MedMutual.com/Provider and select Tools and Resources, Care Management, Prior Approval and Investigational Services Resources. Providers should check beneficiary eligibility to ensure that they have the correct insurance monthly.

Hospice
ODM Issues Clarification on Managed Care Contracting for Hospice Room and Board; CareSource Changes Requirements
Erin Begin
This week, ODM issued communication to various stakeholders stating that as a results of the directive for Hospice agencies to bill room and boar directly, Hospice providers will need to work with the plans and follow their requirements in order to bill for room and board payments. This means that if a plan requires contracts, the hospice providers will need to work with the plan to set those contracts up. Since contracts can take some time to establish, plans will create single-case agreements with hospice providers to establish the rate that will be paid until the contract is completed. Hospice providers should also note that plans may or may not require prior authorization (PA) for hospice services. OHCA is working to confirm with the MyCare plans if their contracting requirements have changed.
ODM has provided additional guidance to the plans regarding this policy update (September 2019). Per the memo that was sent to the plans, hospice providers will not need to request a new PA for hospice services if an approved PA is already on file from the nursing facility – and the hospice provider shall be paid for those previously authorized services (until the authorization’s end date, if applicable). Furthermore, to ensure that hospice providers have enough time to make any additional necessary adjustments (contracts, single case agreements, PA submissions), ODM has instructed the plans to pay hospice providers for claims submitted with dates of services between July 1, 2019 to October 15, 2019 regardless of if a PA is on file. These claims are still required to be properly submitted by the hospice provider.
Hospice providers should note that beginning October 16, 2019, for any member newly receiving hospice services, plans may begin denying payment to hospice providers if a PA for services is not requested or a contract/single-case agreement is not established if either is required by the plan.
AAdditionally, Caresource has begun issuing letters to nursing facilities instructing them to choose an in-network hospice by October 16. OHCA has requested an extension of this contracting cut over since there has been no notification to hospices of the requirement to have a contract. Caresource historically has always had the hospice bill room and board, and was not impacted by the directive from ODM. The decision to require contracting should be published under notifications so that Hospices may have time to complete the requirement. OHCA has also requested assistance from ODMs Managed Care Policy group as well as Caresource leadership, as this also has implications for the hospice if the beneficiary does not choose to change hospice providers. Per the conditions of participation, a hospice may not discharge due to an inability to pay. In the interim, hospice agencies are encouraged to submit credentialing applications at your earliest convenience to avoid issues with non-payment or unnecessary transfer of care during our patient’s final days. OHCA has confirmed with Caresource that their network is currently open for new hospice providers.
Furthermore, United healthcare has confirmed that while their network is open to hospice contracting, they are not requiring hospice companies to be in network for room and board payment.
For questions or concerns please contact Erin Begin.
2019 OHCA Photo Contest Opens Monday!
Steve Mould
Don't forget to review your photos for the best one from the past year! OHCA will kick off the 2019 Long Term and Post Acute Care Services and Supports Photo Contest on September 16. The Photo contest is a program designed to capture life and caregiving through photography. OHCA member providers are invited to submit their best photograph featuring the daily life, activities, loving care and relationships between those we serve, families and staff. Entries should represent some aspect of daily life in long term care, including staff interactions, activities, therapies, events and pets; resident portraits may also be submitted. The public will have an opportunity to vote for entries via the OHCA Facebook page; all entries will be available for viewing and voting on Facebook beginning September 30, 2019. Members submitting an entry will be notified in advance of the display dates so they can publicize and solicit votes for their entries. Please watch for details, entry forms and photo releases on the www.ohca.org website and in next week's Bites.
Candida Auris is on the Rise
Steve Mould
The CDC identified that Candida Auris is on the rise. Candida Auris is a type of yeast that has been causing severe illness in residents and patients in a variety of health care settings, including long-term care. The yeast can enter the bloodstream and spread throughout the body causing serious invasive infections. Unfortunately, this strain of yeast does not respond to common antifungal drugs, making infections more difficult to treat. People at highest risk of infection with this type of yeast are people who have been hospitalized or live in a healthcare facility a long time, have central venous catheters, or other lines or tubes entering their body, or have previously been receiving antibiotics or antifungal medications. Common symptoms include fever and chills that don't improve after antibiotic treatment for suspected bacterial infection. Only laboratory testing can diagnose Candida Auris infection. The Centers for Disease Control and Prevention (CDC) is alerting U.S. healthcare facilities to be on the lookout for Candida Auris. For more information on Candida Auris, refer to the CDC website. Centers are encouraged to review their infection prevention and control programs to identify if updates are needed to address this issue.
CDC Alzheimer's Disease and Healthy Aging Data Portal
Mandy Smith
The Alzheimer's Disease and Healthy Aging Data Portal provide easy access to national and state-level CDC data on a range of key indicators of health and well-being screenings and vaccinations, caregiving, and mental health, including subjective cognitive decline among older adults at national and state levels. These indicators provide a snapshot of currently available surveillance information and can be useful for prioritization and evaluation of public health interventions. Providers can create a custom report, customize visualizations, download data, and more.
CDC Releases Spanish Infographics Ohio Level Data
Mandy Smith
The CDC has released new reports specific to Hispanic adults. Providers can search combined national data as well as state-specific data on the reports page. Español (Spanish) Infographics Featuring Combined 2015-2017 Data from the Behavioral Risk Factor Surveillance System (BRFSS). Ohio reports provided in English, as well as the new Spanish reports, are linked below.
OHCA Budget, Regulatory, Legislative Update/Region Meeting; September 20 in Bellville
Kathy Chapman
TOHCA Regional Meetings are specifically designed to give the busy long-term services and supports professional, in a brief but informative luncheon program, an opportunity to learn about key topics affecting assisted living and skilled nursing providers today and to interact with OHCA staff. You won't want to miss a timely review of the 2020 - 2021 state budget and its impact on LTC service providers. For details and registration please click here.
The E Series: Culture Driven Recruitment and Retention
Kathy Chapman
Are you struggling to get and keep the best people? Are you spending tens of thousands of dollars to fill open positions? Are you craving education to stop the bleed and do things differently? OHCA has contracted with the Drive team to compile the best advice and quick wins they have uncovered into a step-by-step program: The E Series: Culture Driven Recruitment and Retention. Beginning October 9 with "Energized Employees: Thank Goodness It's Monday!," The E series consists of five high-energy, information-packed, 90-minute webinars and two inspiring in-person sessions over the course of seven months. This time frame allows organizations enough time to create sustainable change, not just bandages that don't stick! The program is designed for anyone who hires or is involved in the hiring process, including leaders, department directors, and managers. The program will provide deliverables you can use immediately:
- A worksheet for determining the cost of recruitment/retention
- Focus group questions and tips
- Audit form for website and online presence of the organization
- Sample job postings
- Sample interview questions
- Interview guidelines and process flow
- Guideline for creating magical moments
- Orientation assessment and tips
- Ten must dos for orientation
- Coaching documents and guidelines
- Checklist for ensuing sustainability of recruitment/retention changes.
A tip sheet on turnover from Drive is available here. For program details and registration please click here.
OHCA Fall Conference is Right Around the Corner!
Pete Van Runkle
This year’s Fall Conference is scheduled for October 10 and 11 at the Hilton Easton in Columbus. As always, this day-and-a-half event features numerous sessions with up-to-the-minute information on key topics of interest to Ohio long-term care leaders, not to mention 9 continuing education credits. Among the key sessions are Robin Hillier on important lessons from the first ten days of the Patient-Driven Payment Model and the latest on the Requirements of Participation with Carol Rolf and Michele Conroy. We also have invited State Medicaid Director Maureen Corcoran to discuss the state’s initiatives and priorities for Medicaid, including re-procurement of Medicaid managed care contracts. You should receive the conference brochure shortly. Use this link to register for this highly informative program!
In the News
Steve Mould
OHCA is providing In the News, a summary of stories of interest to busy LTC Administrators and others in 100-words-or-less. The compilation is provided by Drew Vogel, CNHA, FACHCA, a long-time OHCA member with nearly 30 years' experience as an administrator. Prior to that he spent 25 years as a radio reporter, honing his skill at condensing news reports. As the Ohio Mentoring Coordinator for the American College of Health Care Administrators Drew provides this compilation to ACHCA members nationally and is making it available to OHCA members, as well. The latest issue is available here, and on the OHCA Website here.
Association News/Services
AHCA/NCAL Quality Awards
AHCA has announded that the National Quality Award Program 2020 application packets are now available online. In addition, the 2020 program calendar and submission checklist have been posted to each award level page. We hope you'll consider applying for this prestigious award. Participating in the program has many benefits:
- It provides a proven framework that organizations can use to make improvements in any clinical, quality or other operational issue (i.e. staff engagement, customer satisfaction, hospital readmissions).
- It prepares organizations to meet regulatory requirements and navigate a changing market.
- It serves as a team building activity to engage staff across all levels of the organization.
- Organizations gain national recognition and external validation for their care and services.
- It serves as a marketing resource for consumers, referral sources and other key stakeholders.
- Participants receive customized feedback with their top strengths and improvement areas.
OHCA is offering a Bronze Quality Award Workshop on September 20; the program will help you learn how to improve your chance of successfully earning the Bronze Quality Award; begin working on your application for submission; receive expert advice and answers to your questions, and leave with a great start and a clear action plan for completing and submitting your Bronze Award application.
For current Bronze Quality Award recipients, a Silver Quality Award Application Workshop is scheduled for September 18 - 19. This workshop provides a blueprint for successfully preparing your 26-page application. The new Silver Award criteria requires applicants to respond to 7 Baldridge Categories with 17 item requirements. The workshop uses a combination of lecture, case study, examples and exercises to develop and reinforce skills and is designed for first-time applicants and prior Silver Award applicants who were not recipients. For details and registration please go here.
Deficiency Free Facilities
Steve Mould
As part of an ongoing effort to recognize member facilities for their quality improvement efforts, the Association recognizes members that have completed their annual survey with no deficiencies. Please be aware that ODH has suspended its practice of sending providers deficiency free letters, and no longer provides OHCA a list of deficiency free surveys so that we can recognize our members who achieve this success. OHCA would like providers to notify the association if they have a health and LSC deficiency free survey by contacting OHCA Communications Director Steve Mould and providing him their 2567 report. For recognition from OHCA, deficiency free is considered having no citations in certification, licensure and life safety code. To order "We' re Deficiency Free!" buttons for your staff, please download the order form and mail or fax your order to the Association offices.
Heroes Needed!
Steve Mould
Nominate your Hero of Long-Term care today! The OHCA Heroes of Long-Term Care program honors individual long-term care employees for their service to residents, the facility, and to their community. Heroes are nominated from long-term care employees across the state. The program is also intended to provide good news opportunities for use in local and statewide markets. Program details and copies of the Heroes of Long-Term Care nomination form are available at Heroes of Long-Term Care.
Free Job Posting Available to Members
Steve Mould
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. For additional information contact Stephen L. Mould, APR (smould@ohca.org), 614/540-1325.
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OHCA News Bites
OHCA News Bites is distributed electronically each week (except for holidays and special occasions). Member representatives who would like to be added to or deleted from the distribution list should send an email to Debbie Jamieson (djamieson@ohca.org), including the individual's name, company, and email address. Individuals will be added to the email listing for all of OHCA's electronic bulletins and publications