June 3, 2020
Quick Links:
Thursday June 4 at 11 AM:
DQA Webinar on COVID-19 and LTC

Meeting ID:
948 1795 1711 
Password: covid19 

By Phone: 
(312) 626-6799 
Meeting ID: 94817951711#
Participant ID: #

Thursday June 4 at 3 PM:
CMS Webinar on Implementation Strategies for COVID-19 Surveillance and Early Detection

Advance Registration Required: Register here.

Friday June 5 at 7 AM:
DHS COVID-19 Webinar for Health Care Providers

Click HERE to join the webinar

Or dial:
312 626 6799 or 646 558 8658

Webinar ID:
233 994680
COVID-19 Updates: June 3, 2020
This update includes:
  • WHCA/WiCAL Reaches Out to DQA, AHCA about Worrisome CMS Survey/Enforcement Memo
  • HHS Releases Guidance on Important CARES Fund Questions
  • Important Updates re: Specimen Acceptance Criteria Resource and Gold Cross Courier Pickup
  • Caregiving Taskforce Identifies Policy Priorities for Evers Administration
  • Announcement on National Assisted Living Week
As of today, there are 19,400 confirmed cases of COVID-19 in the state of Wisconsin and 616 deaths caused by the virus. Click HERE to view the latest outbreak information from the Wisconsin Department of Health Services. Click HERE to view COVID-19 projections for Wisconsin and the United States.
WHCA/WiCAL Reaches Out to DQA, AHCA about Worrisome CMS Survey/Enforcement Memo
After reviewing CMS 20-31-All , published by CMS on June 1, WHCA/WiCAL has contacted the state survey agency and the American Health Care Association to seek answers to what appears to be a new approach to addressing the COVID crisis in nursing homes.

For more background on the memo, please see WHCA/WiCAL’s June 2 COVID Update article titled, “Punitive Measures in CMS Survey Memo.”

See also this AHCA/NCAL report on the memo , along with other issues.

In a communication to DQA, WHCA emphasized that the new CMS memo on survey activity/penalties is very worrisome for providers, and on its face appears to be a 180-degree change from the collaborative partnership approach that CMS and DQA had indicated they wished to pursue to advance the shared goal of providing quality care in an uncertain and unprecedented time.

WHCA requested an opportunity to discuss with DQA how state surveyors will work with providers given this new framework for penalties and enforcement. The communication also asked for several points of clarification, as the memo included some inconsistencies and confusing references.

DQA officials indicated they are currently seeking additional information from CMS. CMS held a call today with state survey agencies across the country, in which CMS walked agencies through the memo and pointed out deadlines. However, no new information about the memo was shared, and WHCA/WiCAL still has questions and concerns on the penalty/enforcement plan, answers to which we will continue to pursue.

Likewise, WHCA/WiCAL President & CEO has reached out to AHCA to see what the national association is doing to push back on this difficult new development. AHCA staff have indicated they are having conversations with federal officials about provider concerns with this new approach.

The WHCA/WiCAL Survey and Regulatory Committee will also be meeting next Thursday, June 11 to discuss this and other survey and regulatory matters.

Please direct any questions you may have on this memo to jstoa@whcawical.org
HHS Releases Guidance on Important CARES Fund Questions
Late yesterday, June 2, HHS released updated FAQs with long awaited guidance on Tax Identification Numbers (TIN) and has explained use of Gross Receipts. In addition to the TIN s FAQs, HHS also added or updated other FAQ topic areas. That information is listed below the TIN information. To find updated, Gross Receipts language, AHCA/NCAL recommends downloading a copy of the FAQs as a PDF and conducting a key word search.


  • In the case of a parent organization with multiple billing TINs that may have each received payment, may the parent organization attest to the Terms and Conditions and keep the payments?
  • In the case of a merger of a provider entity (billing TIN) into another entity (billing TIN), or the consolidation of two or more entities (each with a billing TIN), resulting in the creation of a new entity (single billing TIN) between January 1, 2018 through January 31, 2020, how should the entities apply?
  • A parent entity submitting an application for a General Distribution payment from the $20 billion payment tranche has more than 20 subsidiaries with Billing TINs. How should it complete the application in the Provider Relief Fund Payment Portal?
  • A parent entity files a tax return (“Filing TIN”) but does not bill Medicare. The parent entity has one or more subsidiaries that bill Medicare (“Billing TIN”) but do not file tax returns (disregarded or consolidated entities). Accordingly, the parent entity did not receive a payment under the $30 billion General Distribution and entering the parent’s Filing TIN does not allow the Provider Payment Portal application to proceed. How should this be addressed with respect to the application?
  • Can a parent organization transfer Provider Relief Fund payments to its subsidiaries?

Other New FAQ Information

HHS also has added or modified language on the SNF Allocation, High Impact Allocation. Other themes in updates are:

Eligible Uses of Fund Dollars

The Terms and Conditions state that Provider Relief Fund payments will only be used to prevent, prepare for, and respond to coronavirus and shall reimburse the Recipient only for healthcare-related expenses or lost revenues that are attributable to coronavirus. What expenses or lost revenues are considered eligible for reimbursement? (6/2)

Resubmission of Information

  • I submitted my revenue information in the Provider Payment Portal. Why am I being asked to resubmit my information?
  • What action should I take in order to resubmit my revenue information?
  • Will the amount of the potential payment be affected if my submission has been identified for resubmission?
  • Do all providers who submitted revenue information in the Provider Payment Portal have to resubmit their information?
  • If I changed my mind after I rejected a Provider Relief Fund Targeted Distribution payment through the Attestation Portal and returned the payment, can I receive a new payment?

Executive Compensation

  • What is the definition of Executive Level II pay level, as referenced in the Terms and Conditions? 

Change in Ownership

  • How should an organization currently undergoing a change in ownership to purchase a practice report revenue in its application?

AHCA/NCAL recognizes an array of unanswered questions remain including additional detail on CHOW and the 10 Day Reporting window included in the Terms and conditions. HHS appears to be following through on its promise to address questions and, as soon as additional information is available we will share it.
Important Updates re: Specimen Acceptance Criteria Resource and Gold Cross Courier Pickup
The following message was sent to the Division of Quality Assurance (DQA) listserv:

Testing continues to be a key strategy for identifying individuals who have COVID-19 and in limiting the spread to others. Approximately 93% of nursing home and ICF/IID providers are testing or have tested their residents and staff as of today.

Specimen Acceptance Criteria Resource
In follow up to the message sent on Friday, May 29th regarding specimen acceptance best practices, please also see the COVID19 Testing: Help Your Specimen Get Accepted resource.

Gold Cross Courier Pickup
Gold Cross Courier will provide coolers and cold packs to transport samples to Exact Sciences. When they arrive at a facility, Gold Cross will remove the samples from the facility container and place them in refrigerated Gold Cross Courier containers. They will transport the samples to the Exact Sciences lab, where the samples will be transferred to Exact Sciences containers for testing.

Previous instruction was to have the box/cooler sealed and labeled for delivery to Exact Sciences. Now, we ask that the sealed biohazard bags be placed in a clear, gallon size resealable bag. Place the Transport Manifest in one of the clear resealable bags, if there is more than one. The outside of each clear resealable bag should be labeled:

  • To: Exact Sciences
  • From: <Facility name>

The facility name listed on the bag should match the name listed on the TRFs. Consistency is important in order to ensure specimens are matched correctly. Keep samples refrigerated until Gold Cross Courier arrives to pick them up; this can be done in the unsealed coolers or another method if preferred. The samples must be refrigerated at 2-8°C until the courier arrives.
Please refer to the resources under “Testing Criteria” on the COVID-19: Long-Term Care Facilities and Services webpage.

If you have questions about the testing process or suggestions for other publications that would be helpful, please email WI COVID-19 SNF Testing.
Caregiving Taskforce Identifies Policy Priorities for Evers Administration
A state task force focused on caregivers identified policies last week that it plans to flesh out this summer for potential recommendations for Gov. Tony Evers' next state budget.

The Governor's Task Force on Caregiving met virtually Thursday. It's planning to take a final vote on recommendations later this year.

“This is really kind of a temperature check at this point,” said Carrie Molke, director of the Bureau of Aging and Disability Resources at the Department of Health Services. “Is there sufficient support for us to keep moving forward and does it warrant that further development?”

The measures identified by the task force include:

  • Developing a pilot program for a screening tool that assesses caregivers' health and well-being.
  • Expanding coverage in the Wisconsin Family Medical Leave act to include chronic conditions and caregiving responsibilities as well as expanding the list of those covered to include grandparents, grandchildren and siblings. 
  • Creating a tax credit for qualified expenses incurred by a family caregiver to assist a family member.
  • Requiring hospitals to provide instructions to family caregivers on the medical tasks they’d have to perform following the discharge of patients.
  • Requiring the Department of Health Services to implement a statewide rate band for some long-term care programs by the end of 2021.
  • Developing a statewide standard for training direct support professionals. 
  • Establishing an 85 percent medical loss ratio for managed care organizations in the Family Care program. 
  • Creating a marketing campaign to recruit direct support professionals.

Two measures, both related to COVID-19, won’t move forward through the task force.

One would have barred the DHS Office of Inspector’s General from conducting audits and recoupments during the public health emergency and require DHS to create a comprehensive guidance document that includes a list of all temporary regulatory flexibilities granted to community-based providers during the crisis.

The other would have continued a rule suspension created through the emergency that allowed 16- and 17-year-olds to work as resident care staff at community-based residential facilities with certain restrictions.
WHCA/WiCAL 4th Annual Quality Symposium to be Moved to 4-Part Webinar Series
With respect to the health & wellness of attendees and presenters, the 4th Annual Quality Symposium will be held as a webinar series and presented in four, 1.25 hour-long webinars, on July 8, July 9, f July 15, and July 16 instead of an in-person event.

The Quality Symposium will bring clinicians and administrators up to date on key issues affecting nursing facilities. This will include an overview of SPADES which are effective October 1, 2020, Infection Control issues including COVID-19 information, and a deep dive into two key areas of compliance – Pressure Injury and Accident/Falls. We will use a case study to demonstrate how your facility can use the Critical Element Pathways to complete the Root Cause Analysis and QAPI process.

Part 1: July 8 | 1:00 - 2:15 PM | Current Infection Prevention and Control Challenges and Expectations in Long-Term Care Settings | Speaker, Diane Dohm of Metastar
Part 2: July 9 | 1:00 - 2:15 PM | How should you respond to Accidents/Falls – A Case Study | Speaker, Lisa Thomson of Pathway Health
Part 3: July 15 | 1:00 - 2:15 PM | Spades: Are You Playing with a Full Deck?| Speakers, Caryn Adams or Bedrock HCS & Pat Boyer of WHCA/WiCAL 
Part 4: July 16 | 1:00 - 2:15 PM | How should you respond to Pressure Injuries – A Case Study| Speaker, Toni Kettner of Superior Health Alliance
Attendees must be present all four sessions to receive NAB continuing education credits; partial credits are not granted by NAB. Education has been submitted to NAB for Distance Learning approval for 5 continuing education credits.
Announcement on National Assisted Living Week
The National Center for Assisted Living (NCAL) shared the below message yesterday:

In light of the challenges brought on by COVID-19, it is even more essential to celebrate National Assisted Living Week (NALW) this year which will take place September 13- 19, 2020. The theme, “Caring is EssentiAL,” is more relevant today than in recent years and highlights the incredible care provided by essential caregivers in assisted living communities across the country.

Additional information will be available on our website in the coming weeks. Please visit and continue to check back on the NALW page for a revised list on how to celebrate NALW and for limited merchandise to show your appreciation for your incredible caregivers.

For the latest information and resources about COVID-19, visit ahcancal.org/coronavirus.

Thank you for your continued support and dedication to the residents you serve and protect.
John Vander Meer, MPA | President & CEO | john@whcawical.org

Jim Stoa, J.D. | Director of Regulatory Affairs and Government Relations | jstoa@whcawical.org

Pat Boyer, MSM, RN, NHA | Director of Quality Advancement and Education | pat@whcawical.org

Kate Dickson, MPA | Director of Reimbursement | kate@whcawical.org

Kate Battiato, MPA | Director of Workforce Development | kbattiato@whcawical.org

Allison Cramer | Communications and Government Relations Specialist | allison@whcawical.org

Jena Jackson | Director of Development | jena@whcawical.org

Jammie Moore | Director of Administrative Services | jammie@whcawical.org

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