07/08/2020
Today's COVID-19 Report: Wednesday, July 8, 2020
Wednesday, July 8, 2020
Here are the latest need-to-know updates for Wednesday, July 8 regarding the COVID-19 pandemic.
LeadingAge Ohio Remembers the Elders Lost to Coronavirus
Today, LeadingAge Ohio joins LeadingAge and the Global Aging Network to remember the elders of coronavirus. On this day of global mourning and remembrance for older adults lost to COVID-19, aging services providers, health care workers, and communities around the world are honoring hundreds of thousands of older lives lost.
LeadingAge Ohio sent a press release on the day of remembrance and to urge leaders for great supports in the sector.
You Asked... We Answered
Mollie Gurian, Director of Hospice, Palliative and Home Health Policy for LeadingAge, shared some information on a situation that many hospice providers may have encountered during the pandemic.
You Asked: When a patient is on hospice and contracts COVID-19, is the case of COVID-19 considered unrelated to the terminal prognosis? It is a diagnosis that could alter the prognosis, but is not one of the diagnoses that contributed to the determination of medical prognosis upon hospice admission. This begs the questions if the COVID-19 diagnosis occurs after hospice admission and a nursing home plans to isolate the patient and pay for it by putting them on the Medicare SNF benefit for skilled care, is that acceptable because COVID-19 is not related to the terminal prognosis? Would the hospice need to pay for that skilled care under their per diem?
We Answered: According to the Centers for Medicare & Medicaid Services (CMS), "the reported principal diagnosis is that which is most contributory to the terminal prognosis of the individual."
CMS officials went on to say, "Because hospice eligibility is predicated on a terminal prognosis, CMS' position has always been that it is often the result of multiple conditions that render an individual as terminally ill. For example, if an individual has been certified as terminally ill with lung cancer being the diagnosis most contributory to the terminal prognosis, but the individual also has congestive heart failure, the congestive heart failure also contributes to the overall condition of the individual being terminally ill. Clinically, body systems are interrelated, making it difficult to assert that any discrete condition is “unrelated”, especially when an individual is approaching the end of life.
"In the scenario above, the argument is that COVID-19 is 'unrelated' as it is not the condition that rendered the individual as terminally ill as part of the hospice certification. However, if a condition arises after certification that potentially alters the course of the individual’s life expectancy (e.g., COVID-19), it is difficult to rationalize how COVID-19 would be unrelated to the individual’s terminal prognosis."
CMS stated that the hospice would have to revisit its contract with this nursing home to see what it says in regards to a situation such as this. Furthermore, a hospice cannot discharge because of a patient being more costly as a hospice can only discharge a beneficiary for three reasons: the patient is no longer terminally ill; the patient is no longer in the hospice’s service area; or for cause (see 42 CFR 418.26).
Therefore, if the nursing home has the hospice patient in a SNF bed for isolation purposes for COVID-19, it could not separately bill Medicare for such care, as it is duplicative if the hospice is being paid to furnish nursing care. CMS encourages hospices to discuss these arrangements with the nursing home to determine the best way to continue caring for these patients.
Palmetto RCD Questions Can Be Answered Over Email
The Palmetto GBA Review Choice Demonstration (RCD) Provider Outreach and Education (POE) team contacted LeadingAge Ohio to share the best way for LeadingAge Ohio members to obtain assistance. The team shared that they have an email account dedicated to the RCD and questions.
To Avoid Delays in Research or Response:
- Send RCD questions or concerns to rcd.poe@palmettogba.com. This will ensure inquiries are documented in the tracking system and answered timely.
- Avoid sending emails directly to RCD POE staff.
- Include as much information as possible. Screenshots, DCNs, Provider Contact Center (PCC) Inquiry Tracking / Reference Number, etc. Please do not send any PHI/PII!
- Remind your members to first contact the PCC. The PCC is knowledgeable and can resolve many RCD concerns. If your members are not satisfied, they should obtain the PCC Reference Number.
Feedback and recommendations are strongly encouraged to make the RCD process a better experience for all. Many RCD questions can be answered on the Palmetto GBA website and the CMS website. Specific questions or concerns should always be first addressed to the PCC. They log and track all RCD inquiries.
Hospice Quality Reporting Resumes
As part of one of the 1135 blanket waivers, the Centers for Medicare & Medicaid Services (CMS) exempted data from Q1 and Q2 of 2020 (Jan 1-June 30, 2020) from various provider quality reporting programs (SNF, home health, and hospice).
The data submission for these programs has restarted and CMS put out a tip sheet regarding submitting data for the Hospice Quality Reporting Program. The tip sheet provides practical guidance to address hospice quality data submissions starting on July 1 now that the temporary exemptions have ended.
Hospices are expected to resume timely quality data collection and submission of CAHPS® Hospice Survey and hospice item set (HIS) records. The CAHPS® Hospice Survey starts July 1 with July deaths. HIS also starts July 1 with all new HIS admission records and any HIS discharge records that occur on or after July 1. The CY 2020 data used for meeting the Hospice Quality Reporting Program requirements include July 1-December 31 since CMS exempted Q1 and Q2 of 2020 (January 1-June 30).
LeadingAge, ElevatingHOME, VNAA Comments on Home Health Guidance Expanding Practitioners That Can Order Services
Today, comments on behalf of LeadingAge, ElevatingHOME, and VNAA were submitted in support of the guidance that the Centers for Medicare & Medicaid Services (CMS) released to expand the ability for non-physician practitioners (nurse practitioners, certified nursing specialists, and physician assistants) to order and certify home health services for Medicare and Medicaid.
This permanent change was made in the CARES Act legislation, and CMS was given 6 months to issue guidance and implement, which they met early with the interim final guidance effective as of May 8. While state laws may still require roles for physicians depending on scope of practice rules, this is a significant step forward for greater access to home health services.
Medicare Webinar: Online Tracking Feature of Medicare Part A Cost Report e-Filing
LeadingAge shared information about a Centers for Medicare & Medicaid Services (CMS) webinar on the new online tracking feature of the Medicare Part A cost report taking place this Thursday July 9 from 1:00-2:30pm. Registration is available online.
The webinar will educate Medicare Part A providers about updates to the Medicare Cost Report e-Filing (MCReF) system that allow tracking from submission through finalization. Topics include:
- Overview of new online status tracking, including functionality and layout
- Recap of how to access the system and transmit the cost report
- Frequently asked questions
A question and answer session will follow the presentation; however, attendees may email questions in advance to OFMDPAOQuestions@cms.hhs.gov with “Medicare Cost Report e-Filing System Call” in the subject line.For more information, see the MCReF (PDF) MLN Matters Article and MCReF webpage.
Affordable Housing Action Alert on COVID-19 Relief
Today, an action alert was sent nationwide to all LeadingAge members asking them to tell their U.S. Representative and Senators to co-sponsor The Emergency Housing Assistance for Older Adults Act (S 4177, HR 6873). The $1.2 billion in financial support provided by the Emergency Housing Assistance for Older Adults Act (S 4177, HR 6873) must be included in Congress’ next COVID-19 relief package.
Ask your members of Congress to help the more than 700,000 older adults nationwide in HUD-assisted housing.
HUD Issues Evictions Guidance
The U.S. Department of Housing and Urban Development (HUD) published additional information for owners and residents of HUD-assisted housing about the expiring evictions moratorium. To help communities navigate what could be an impending “evictions cliff” after the CARES Act moratorium expires on July 24, HUD’s Office of Multifamily Housing issued a Notice on tenant protections and forbearance for HUD-assisted housing communities; HUD also issued a brochure to help multifamily property owners promote housing stability during the pandemic.
Housing Happenings Call: Importance of Documentation Emphasized
Juliana Bilowich, LeadingAge’s Director of Housing Operations and Policy, hosted this morning’s Housing Happenings call; she provided three important HUD updates.
(1) Earlier today, HUD released a memo on vacancy claims, providing special processing guidance for the claims (e.g. if a unit couldn’t be readied for occupancy due to COVID-19, flexibility is offered). HUD’s intent is to seek consistency in reporting requirements for providers and LeadingAge will push for clarification on the kind of documentation HUD will require, if any, to meet the requirements.
(2) HUD has indicated that REAC inspections will not begin before the end of the fiscal year (September 30). When inspections do resume, Bilowich reported that flexibility appears to remain central to HUD’s phased REAC re-start; good news – senior housing providers will be exempt for the first phase of the REAC re-start. Providers with concerns about how COVID-19 will impact REAC inspections (or how NSPIRE and REAC are connecting during this time) are encouraged to email Kathryn Brod at kbrod@leadingageohio.org.
(3) The $50M allocated to housing providers as part of the CARES Act is likely going to be released through an application process. “Document! Document! Document!” Juliana urged. Providers should maintain documentation of the added expenses each property has incurred resulting from COVID-19.
As re-opening challenges continue across the country, these weekly calls also allow providers to share best practices on safety, programs and services. Lisa Berkemeier, HUD Housing Administrator with Graceworks Lutheran Services, shared her organization’s work to understand how best to respond to residents’ needs in the reopening process. Complete summaries of these weekly calls can be found on the LeadingAge Ohio COVID Hub. Housing Happenings calls will continue every Wednesday morning at 9AM. Call details and registration information can be found on the LeadingAge Ohio website.
No Cost COVID-19 Pop-up Testing Sites in Cincinnati, July 6-12
The Ohio Department of Health (ODH) shared that free COVID-19 pop-up testing sites in the Cincinnati area will be active from July 6-12. Members located in the pop-up testing site areas can utilize the sites for no cost and share with other providers, friends, and families in the area.
Scripps Shares Satisfaction Survey Data
Miami University's Scripps Gerontology Center was not surveying families for the Ohio Nursing Home and RCF Satisfaction Surveys this summer, so it took advantage of the opportunity to research the family experience in long-term care during the COVID-19 visitation restrictions.
Scripps has shared that the full report can be viewed here.
Reporting Not Due on July 10 for Provider Relief Fund
Providers have been inquiring about what they need to report by July 10 to HHS. The CARES Act and the provider relief fund (PRF) Terms and Conditions that providers signed for each payment they received require quarterly calendar reporting. The first report was scheduled to be due July 10 to HHS and the Pandemic Response Accountability Committee.
However, as HHS noted in an FAQ on June 19, “Recipients of Provider Relief Fund payments do not need to submit a separate quarterly report to HHS or the Pandemic Response Accountability Committee. HHS will develop a report containing all information necessary for recipients of Provider Relief Fund payments to comply with this provision.”
This does not mean future reporting won’t be required, but providers do not need to submit anything by this Friday, July 10. The FAQ also stated, “HHS will be requiring recipients to submit future reports relating to the recipient’s use of its PRF money. HHS will notify recipients of the content and due date(s) of such reports in the coming weeks.”
LeadingAge will communicate this information to members as soon as it is available from HHS. CliftonLarsonAllen has created an expense tracking tool to assist fund recipients in staying compliant.
Governor Announces Mask Mandates, Information on Long-term Testing
Governor DeWine announced yesterday that effective today at 6:00 p.m., a new Ohio Department of Health (ODH) order will mandate face coverings in public in all counties that are designated as a Red Alert Level 3 Public Health Emergency or a Purple Alert Level 4 Public Health Emergency.
Currently, seven counties in Ohio (Butler, Cuyahoga, Franklin, Hamilton, Huron, Montgomery, and Trumbull) are designated at Red Alert Level 3 which indicates that those in these counties have a very high risk of exposure and spread. As of today, no counties have reached Purple Alert Level 4, however, Franklin County is approaching this top tier.
During questions, Governor DeWine also noted that once the Ohio National Guard completes its baseline test of all nursing home staff and some residents, repeat testing programs will be instituted by providers. LeadingAge Ohio will be working with the Administration to determine what supports will be available to providers as we move into this new phase of testing. To date, no specific details have been formally released related to the next phase of testing.
LeadingAge Need to Know: COVID-19 – July 8, 2020
LeadingAge shares the latest coronavirus news and resources with members twice each weekday. This morning's update featured a message from LeadingAge president and CEO, Katie Smith Sloan today's special day of remembrance for the Elders of Coronavirus and new tools and resources from LeadingAge.
Check out the full report here.
Questions
Please send all questions to COVID19@leadingageohio.org. Additionally, members are encouraged to visit the LeadingAge Ohio COVID-19 Working Group facebook group to pose questions to peers and share best practices. LeadingAge is continuing its daily calls for all members. To participate in these daily online updates, members should register at here.