Coronavirus Update #24
CMS Prioritization of Survey Activities, CRISP Update, and Reminders
General Update and Thank You

Thanks for all you are doing as we face together the COVID-19 pandemic. You and your teams are doing what you have been doing day in and day out for decades: providing quality care to Marylanders in need, helping families, and saving lives. 

Please know that we are continuing to work with our partners across the continuum at the state level and with AHCA/NCAL at the federal level to continue advocating for you and your teams regarding regulatory and financial relief, Medicaid waivers and eligibility processing, staffing challenges, supplies and testing shortages, reporting of bed capacity, and other operational concerns.

Yesterday Governor Hogan took further action to add an additional six thousand acute beds to Maryland’s existing acute care capacity. Governor Hogan is doing an outstanding job preparing Maryland hospitals for the acute care surge. That said it, it will take all of us working together.

We have learned from other states that COVID-19 hits hard and fast, supplies diminish quickly, and workforce becomes a challenge. Everything we are advocating for with you, to Maryland leaders and in DC with AHCA/NCAL, is aimed at minimizing this in advance the deepening crisis.

Your care teams are and will continue to save lives. Together, we will get through this. There will be an end to this time of emergency. Onward together!
Reminder: SNF Bed Capacity Inventory Survey

  • As we continue to advise, Maryland post-acute providers can accept hard to place non-Covid-19 hospital transfers now in order to help free-up acute care in hospitals for COVID-19 patients.

  • Hard to place patients include those who have high drug costs that are paid for in hospitals, but not in SNFs. We will continue to work with AHCA/NCAL, with our Congressional Delegation, and with the Hogan team for CMS regulatory and financial relief on this front.

  • No decisions yet. But in advance of the acute care surge associated with COVID-19, it is important that we inventory SNF capacity to take non-COVID-19 med/surg patients to free-up acute care space. 

  • For the future, plan now: we strongly urge SNFs to begin now creating separate wings, units, or floors by moving current residents to handle future full surge admissions from the hospitals and keep current residents separate, if possible.

Please complete this SNF bed capacity survey ASAP. Note that this survey should be completed once per center ; please make sure the appropriate person on your team completes the survey.
CMS Prioritization of Survey Activities 

Yesterday, CMS released guidance   prioritizing and suspending most federal and state survey agency (SSA) surveys, and delaying revisit surveys, for the next three weeks beginning on March 20, 2020, for all nursing homes. For non-IJ related onsite surveys that are currently in process, survey teams are instructed to end the survey and exit the facility.  

State and federal surveyors should not enter the building, for any type of survey, if they are unable to meet the Personal Protective Equipment (PPE) expectations outlined by the latest CDC guidance. They may instead obtain necessary information remotely, to the extent possible.  

Federal and state surveyors will conduct targeted infection control surveys of providers identified together with the Centers for Disease Control and Prevention (CDC) and the HHS Assistant Secretary for Preparedness and Response (ASPR). They will use this survey tool   to review infection prevention and control practices.

Surveyors will review for: 

  • Overall effectiveness of the Infection Prevention and Control Program (IPCP) including policies and procedures 
  • Standard and Transmission-Based Precautions (with the understanding that certain essential supplies are scarce, and facilities should not be penalized for not having certain supplies if they are unable to obtain them) 
  • Quality of resident care practices, including those with COVID-19 (laboratory-positive case), if applicable 
  • Surveillance plan 
  • Visitor entry and facility screening practices 
  • Education, monitoring and screening practices of staff 
  • Facility policies and procedures to address staffing issues during emergencies, such as transmission of COVID-19 

Changes in the survey process in effect for the next three weeks include: 

  • Standard surveys and non-IJ revisits are suspended for three weeks

  • ​​​​​​​During this period, the following surveys will be suspended: 
  • Standard surveys for nursing homes, hospitals, home health agencies (HHAs), intermediate care facilities for individuals with intellectual disabilities (ICF/IIDs), and hospices. 
  • Life safety code and emergency preparedness elements of standard surveys. 
  • Revisits not associated with an IJ. 
  • The following enforcement actions will be suspended, until revisits are again authorized: 
  • Imposition of Denial of Payment for New Admissions (DPNA), including situations where facilities are not in substantial compliance at 3 months. 
  • Imposition of termination for facilities that are not in substantial compliance at 6 months. 
  • Per day civil money penalties (CMP) will not accumulate. 
  • CMS will not impose any new remedies for prior noncompliance. 
  • Note: Enforcement actions for unremoved or new IJs remain and will continue to be issued under normal procedures/guidance. 

  • Complaints and facility-reported incidents triaged at the Immediate Jeopardy level will continue

  • During this three-week time frame, State survey agencies (SSAs) and CMS will only conduct surveys related to complaints and facility-reported incidents (FRIs) that are triaged at the Immediate Jeopardy (IJ) level, and revisits to verify removal of IJ (including previously cited IJ deficiencies). 
  • If the revisit survey determines there is continuing noncompliance, but at a lower level than IJ, surveyors will not conduct another onsite revisit survey. 
  • For non-IJ deficiencies, providers may submit a plan of correction (POC) to be held until the end of the three-week period or may delay submission of their POC until the end of this period. 
  • Enforcement actions for unremoved or new IJs remain and will continue to be issued under normal procedures/guidance. 

  • Perform self-assessments on infection control using surveyor tool
  • Use the COVID-19 Infection Control Focused Survey tool contained in the CMS memo (developed with CDC) to perform self-assessment of your facility’s Infection Control plan. This document may be requested by surveyors, if an onsite investigation takes place. 
  • CDC recommends that nursing homes notify their health department about residents with severe respiratory infection, or a cluster of respiratory illness (3 or more residents or HCP with new-onset respiratory symptoms within 72 hours).
  • Note: Local and state reporting guidelines or requirements may vary.  

Expanded guidance to limit visitors across other provider types 

  • In this memo, CMS provides guidance to restrict visitation in health care facilities such as hospitals, critical access hospitals, psychiatric hospitals, inpatient hospice units, and intermediate care facilities for individuals with developmental disabilities. 
  • Nursing homes should continue to refer to QS0-20-14 for visitor guidance. 

Access for health care staff 

  • CMS acknowledges that some providers (nursing homes, assisted living facilities, etc.) have significantly restricted entry of staff from other providers who are providing direct care to patients. In general, if the staff is appropriately wearing PPE, and do not meet criteria for restricted access, they should be allowed to enter and provide services to the patient (interdisciplinary hospice care, dialysis, organ procurement, home health, etc.). 
  • This does not change existing guidance for nursing homes.  

Information for Clinical Laboratory Improvement Amendments (CLIA) 

  • For CLIA, surveyors will prioritize immediate jeopardy situations over recertification surveys, and generally use enforcement discretion, unless immediate jeopardy situations arise. 
CRISP Update

Through the ENS PROMPT application in ULP, CRISP now displays alerts when a patient tests positive or negative for COVID-19 as well as confirmed cases as reported by the Maryland Department of Health (MDH). These alerts are made available to a patient's care team based upon:
 
  • A list of confirmed cases sent to CRISP from the Maryland Department of Health (MDH).
  • Positive and negative lab results from LabCorp and Quest lab feeds across the region. These results currently originate from ordering physicians that are CRISP participants with executed lab request forms within our system. We are actively working with LabCorp, Quest and hospital based testing centers to provide more comprehensive results.
 
*As CRISP receives results from lab feeds that are reported to the Maryland Department of Health, there may be instances of duplicate alerts. This occurrence is expected based upon the reporting workflow established by the State.
 
How to to view COVID-19 alerts within ENS PROMPT:
 
  1. Navigate to the “Add Filter” drop down at the top of the screen.
  2. Select the “Diagnosis Description” category.
  3. A list of options will appear to the right of the category, select “contains”.
  4. Type the term “COVID” into the open field.
  5. Return to the “Add Filter” drop down at the top of the screen.
  6. Select the “Patient Class” category.
  7. A list of options will appear to the right of the category, select “equals”.
  8. Select “O: Outpatient” from the drop down.
  9. Within the “Custom Filter” field, type the desired name of the custom filter then click “Save”.
  10. Once you’ve created the filter, alerts for both positive and negative test results as well as confirmed cases will automatically populate.

Additional Information Regarding COVID-19 Alerts in ENS PROMPT:

  • Saved custom filters will always be stored for future use within the “Saved Custom Filter” drop down. There is no need to repeat the aforementioned steps.
  • Please note, saved filters are not automatically applied the end users notifications. Upon logging in, the user must select and apply the saved custom filters prior to viewing alerts.
 
Patient Snapshot Update

In the Care Team widget, users will be able to see if a particular patient has been added to the list of confirmed cases sent to CRISP from the MDH. To view, users must navigate to “Care Team” widget and locate the “Organization” column. Within this column, any row that contains the “ MDH COVID-19 Outbreak Response ” label indicates that the patient is a confirmed COVID-19 case.
 
Health Records Update

If a user is interested in viewing a patient’s full lab report, it is available through the “Laboratories” section of the Health Records application. Please keep in mind that the lab reports within Health Records are made available to a patient's care team based upon:

  • A list of confirmed cases sent to CRISP from the Maryland Department of Health.
  • Positive and negative lab results from LabCorp and Quest lab feeds across the region. These results currently originate from ordering physicians that are CRISP participants with executed lab request forms within our system. CRISP is working with LabCorp, Quest and hospital based testing centers to provide more comprehensive results.

If you have any questions about this information, please contact William.Hokemeyer@crisphealth.org
CMS Delay of October 1, 2020 MDS Update

As the Centers for Medicare and Medicaid Services (CMS) previously announced, they are delaying the Minimum Data Set (MDS) 3.0 v1.18.1 release, which had been scheduled for October 1, 2020. The MDS item sets are used by Nursing Home and Swing Bed providers to collect and submit patient data to CMS. This MDS data informs payment, quality, and the survey process.

The Maryland Department of Health (MDH) has shared that since implementation of the MDS changes that remove Section G are being delayed, Maryland does not need to require providers to submit the Optional State Assessment (OSA) effective October 1, 2020 in order to maintain the RUG-IV payment system. 
Transfers from SNFs to the Hospital

Please remember that positive test for COVID-19 or a person with fever or respiratory symptoms does NOT need to be hospitalized. They should be put in contact precautions and follow  CDC guidance  for COVID-19 positive or presumptive cases in long term care. If a resident requires IV fluids, oxygen and other treatments due to their respiratory symptoms, Medicare will allow you to switch the person over to Medicare Part A  without a 3-day SNF stay. Discussion with families and residents should occur about the risks of hospitalization with COVID-19 during this pandemic period. 

Our partners at UMMS have developed this SNF to ED transfer form for use when necessary.
Reminder: MEMA - Request for Resources

Centers are now able to make resource requests directly to the Maryland Emergency Management Agency (MEMA). Please see the instructions here.

All requests for resources will now be sent to request.mema@maryland.gov

The MEMA Resource Section will input the information contained in these emails into a WebEOC request (on the requestor's behalf), and task that request to the appropriate fulfilling body. MEMA will have a staffer solely dedicated to monitoring the email account and gathering any necessary data from the requester.  
Did you miss HFAM's previous alerts?

Visit our website to view all previous HFAM alerts, as well as guidance
from our federal and state partners.
Please email COVID19@ahca.org for additional questions, and visit
www.ahcancal.org/coronavirus for additional information and resources.
Thank you.

We cannot thank you enough for the dedication and diligence in doing all that you can for the residents in your communities. HFAM continues to monitor the COVID-19 pandemic with our state and national partners and will do all we can to support you during this time.