04/09/2020

Today's COVID-19 Report: Thursday, April 9, 2020

Thursday, April 9, 2020

Here are the latest need-to-know updates for Thursday, April 9 regarding the COVID-19 pandemic.

This morning, Ohio Department of Aging Director Ursel McElroy joined our all-member update call to discuss COVID-19 with our members. Director McElroy shared many of the resources you will read about below. 

Today's ODM Survey Deadline Extended to Tomorrow, Friday, April 10

Reported in an e-alert earlier today, LeadingAge Ohio received communication this morning from the Ohio Department of Medicaid (ODM) regarding an urgent survey request for all Medicaid-certified nursing facilities. The time frame to complete the survey has been extended after concern was expressed that it was too little time for providers to complete, and the survey is now due by close of business tomorrow, Friday, April 10. 

LeadingAge Ohio is sharing the survey link with all members here, but the subject of the email from ODH will read "SURVEY: Nursing Facility COVID-19 Cost Impacts  *PLEASE COMPLETE TODAY* “.

Both ODM and the Ohio Department of Aging (ODA) stated that while the provider number field is not mandatory, all providers are being urged to provide their NPI. 

ODM is open to allowing multi-site providers to respond with an Excel spreadsheet for the multiple facilities of a single entity. An organization responding in this way should send its spreadsheet to Elizabeth.Effah@medicaid.ohio.gov. The survey is only intended for NF providers, not assisted living or other lines of service. Please complete only one survey per facility. As stated before, the surveys are due by COB tomorrow, Friday, April 10. 

ODM acknowledges that this is a very quick turn-around but stressed the importance of Ohio facilities completing the survey. 

LeadingAge Ohio Updates Q&A Master Document

LeadingAge Ohio has updated our Q&A "master document", which encompasses the complete list of member-posed questions received to-date regarding COVID-19. The lengthy document features a table of contents.

ODA Resources for Senior Housing Providers

During the all-member call this morning with Ohio Department of Aging (ODA) Director Ursel McElroy, Director McElroy pointed LeadingAge Ohio housing providers to a few helpful resources on the ODA coronavirus webpage.

In a letter to Ohio affordable senior housing providers, Director McElroy shared Guidelines for Senior Affordable Independent Housing Communities, which were prepared by ODA alongside the Ohio Department of Health (ODH). The guidelines provide recommendations related to managing properties and supporting residents during COVID-19. 

ODA also shared posters for senior housing providers which provide public-facing communications related to COVID-19. 

ODM Shares Managed Care Waivers

In meetings with the DeWine Administration earlier this week, Medicaid staff shared a list of waivers they are extending for Medicaid managed care and MyCare Ohio programs. These include extensive waivers and suspensions of prior authorization requirements, an extension of timely filing requirements to 365 days, and other flexibilities.

The changes are listed below:

Prior authorization

• PDN. New PDN requests (including requests for additional hours) shall be approved without prior authorization for 90 calendar days.
• Home Health. No prior authorization for the first two weeks of service.
• DME. 90-calendar-day supply of DME without prior authorization from participating and non-participating providers except for the items outlined in the provider agreement (e.g. pain pumps, certain mobility devices, etc.). DME providers shall be paid using the payment rate or methodology described in OAC rule 5160-10-01 (participating and non-participating).
• Nursing Facility Stays. No prior authorization for new NF stays; level of care must still be determined; concurrent reviews may continue to determine if NF services are still necessary.
• Current NF placements (i.e. those that occurred before the pandemic). Plans shall allow all existing prior authorizations to be extended for six months from the renewal or expiration date.

Authorization of MyCare Waiver Services

• All services may be authorized or adjusted based on a telephonic assessment of need between the waiver service coordinator and individual.
• Services for established individuals may be authorized for the duration of the service plan, as determined necessary by the waiver service coordinator.
• If a new service is authorized as a result of telephonic contact with the individual, the new service may be authorized for up to 180 days or until the next face-to-face contact.

Waiver Provider Relief 

• Home Delivered Meals. To ensure individuals have needed meals during the COVID-19 emergency, ODM provided guidance for waiver service coordinators to authorize additional meals. If authorizing additional meals, they should take into consideration the storage capacity of the individual, not the preference of the provider. (Per CMS guidance, CMAs cannot authorize more than two meals per day.)
• In-person/environmental assessment. For any service that requires an in-person/environmental assessment, the individual and provider must be in agreement with the process required for service provision. If there is a service, such as pest control, that may require an individual to leave the home setting for service provision (NF respite stay), waiver service coordinators should consider available alternatives such as arranging a staying with an informal support.
• Telephonic flexibility for waivers. Regarding assessments and contact schedules Ohio is allowing face-to-face requirements to be replaced with telephonic contact.
• Waiver disenrollments. Disenrollments will not be proposed unless the individual: passes away; requests disenrollment; moves out of state; or transitions between a Fee-for-Service waiver and the MyCare Waiver.
• Nursing Facility and Waiver Provider Timely filing Relief. Managed Care Plans (MCPs) and MyCare Ohio Plans (MCOPs) are extending timely filing limits to accept claims from all provider types for up to 365 calendar days from the date of service.
• Increasing waiver provider pool. The State will permit waiver providers with an active Medicaid provider agreement to provide waiver services across delivery systems without being subject to additional provider standards and certification processes specific to waiver programs.
• Transportation. MCPs/MCOPs have implemented transportation protocols due to COVID-19 and are working together to produce a transportation protocol across plans.

Non-participating Provider Requirements

• Single case agreements are not required to pay non-participating providers
• Non-participating, Medicaid-enrolled providers shall be paid the lesser of: 100% of the Medicaid FFS rate; or the provider's submitted charge. 
• Plans do not have to pay providers who are excluded from being Medicaid-enrolled providers due to fraud, waste, and abuse.

COVID-19 Testing and Treatment

• MCOPs will follow Medicare guidelines regarding testing and treatment of COVID-19. MCPs shall cover COVID-19 testing and pay at least 100% of the Medicare rate and use the following testing codes (or any newly developed test): U0001 –CDC 2019 Novel Coronavirus Real-Time RT-PCR Diagnostic Panel U0002 –non-CDC laboratory tests for SARS-CoV-2/2019-nCoV. MCPs and MCOPs shall cover treatment and vaccinations for COVID-19 without restrictions or cost sharing.

Telehealth

• Plans must follow Ohio Administrative Code (OAC) rule 5160-1-18 (“Telemedicine”) and 5160-1-21 (“Telehealth During a State of Emergency”). 5160-1-21 is effective beginning on the date the Governor declared a state of emergency (March 9, 2020).

Reporting Requirements 

• The following information shall be provided to ODM: Documentation on the payment of clean claims on a weekly basis; COVID-19 related reports upon request; implementation status of Appendix S requirements; any reported drug shortages; any potential provider shortages (e.g. home health, behavioral health, oxygen, etc.)
• Reports and information shall be submitted using a format and process prescribed by ODM.

Additional Requirements

• Plans shall not impose any member cost-sharing for state plan services (including prescriptions drugs) during the time Appendix S is enacted. Patient liability remains a requirement for waiver services and nursing facility care.
• Claims shall be accepted from all provider types for up to 365 calendar days from the date of service.
• Follow guidance provided in the “Emergency Protocol” for care management (to be updated periodically as needed).
• Provide notification to providers when a member tests positive for COVID-19.

The Ohio Department of Medicaid has promised further guidance, including FAQs, on the additional waivers in the coming days. LeadingAge Ohio will post the additional information as soon as it is available in a future Daily COVID-19 Report.

ODM Expands Telehealth to LTSS Providers

This week, the Ohio Department of Medicaid (ODM) announced that it would use authority granted in the earlier telehealth executive order signed on March 20 to significantly expand telehealth services. The initial telehealth expansion had applied principally to providers that operate independently: physicians, licensed independent social workers, and PT/OT/SLP. At that point, ODM recognized that the limited expansion didn’t serve the needs of the LTSS providers, and that they would be working on another rule that would expand telehealth to LTSS providers.

Similar to the first expansion, ODM will allow both synchronous and asynchronous services, and the originating and delivery site requirements are very flexible. Care can be delivered almost anywhere. The list of providers who can deliver telehealth includes RN and LPN services that are provided as part of home health or hospice care that are delivered via telehealth; these services can be billed through the agency.

Regarding home health and hospice, ODM has offered the following guidance:

Hospice Services

• ODM is temporarily suspending the face-to-face and in-person requirements found in OAC 5160-56-02 and 5160-56-06. Providers should add the GT modifier to any hospice procedure code on any claims that include at least one telehealth component for that date of service T2042 routine home care.
• T2043 continuous home care (this type of care consists predominately of nursing care; it may involve services provided by a home health aide and/or homemaker services).
• T2046 select direct care / supervision included in room and board payments in a NF (reimbursed at 95% of the NF’s daily rate).
• Service Intensity Add-On (SIA) Codes -G0299 for direct care by in-person visit from an RN & G0155 for direct care by in-person visit from a social worker.

Home health services, RN assessment services and RN consultations

• Telehealth can be used to satisfy the requirement for a face-to-face visit with the provider who is ordering home health services. The provider will still need to complete the appropriate documentation and send it to the home health agency.G0156 Home Health Aide.
• G0299 Home Health Nursing –RN
• G0300 Home Health Nursing –LPN
• T1001 RN Assessment
• T1001 w/U9 Modifier –RN Consultation
• G0151 Physical Therapy
• G0152 Occupational Therapy
• G0153 Speech-Language Pathology

Per the previous order, physician services in nursing homes can be delivered via telehealth. Any other services should be part of the per diem rate and reported on cost report. Telehealth flexibility is retroactive to March 9, and formal guidance is anticipated in the next few days. 

Reminder: Sign Up for EIDC Notifications

Earlier today, LeadingAge Ohio learned that some of its members had not received the provider readiness survey being distributed to all Ohio long-term services and supports providers. ODH is distributing the surveys via the Enhanced Information Dissemination and Communication (EIDC) system, and providers who do not receive updates via EIDC should request access via the ODH website.

Palmetto seeks CMS Clarification on Hospice Telehealth

Palmetto GBA reached out to the Centers for Medicare and Medicaid Services (CMS) to get clarification regarding putting routine health care telehealth visits on claims. CMS provided guidance that hospice routine home care telehealth visits do not need to be documented on hospice claims at this time. Palmetto has asked for additional clarification from CMS on this issue and will share additional guidance with LeadingAge Ohio when they receive it.

Friday Morning ODA Webinars

The Ohio Department of Aging (ODA) has begun holding a webinar each Friday with Ohio's Area Agencies on Aging (AAA) to connect on COVID-19 related developments. Director Ursel McElroy is opening these webinars up to all Ohio providers to join in on the discussion. 

The webinars are held each Friday at 10:00 a.m - including tomorrow, Friday, April 10. Registration is available online. After registering, you will receive a confirmation email containing information about joining the webinar.

Ohio Statistics: 5,512 Cases, 213 Deaths

As of today, there are 5,512 confirmed cases of COVID-19 in Ohio and 213 deaths. A total of 1,612 people have been hospitalized, with 497 Ohioans requiring ICU care. 

In-depth data can be accessed by visiting coronavirus.ohio.gov. 

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.