May 7, 2020
KHCA/KCAL is committed to providing our members with important updates. Below is a list of the most recent COVID-19 updates. Please visit our website for a list of complete updates.  www.khca.org
KHCA/KCAL COVID-19 Update Call on Friday, May 8, 2020 11:00am - 11:30am
Topics for discussion:  
  • Entrance Conference Sheet
  • New Critical Element Pathway for Focused IC Surveys
  • Reporting & Notification – Interim Final Rule
  • Admission Flow Chart
  • CMP Grant Opportunity

Link to register for call:
Facilities must submit their first set of data by 11:59 pm on Sunday, May 17, 2020 to the NHSN Long-Term Care Facility COVID-19 Module.
Late yesterday, CMS released a  QSO memo  addressing the Interim Final Rule requiring nursing homes to report to NHSN on COVID-19 as well as provide notifications to residents, their representatives and families.  

Some highlights from the memo are listed below. AHCA is reviewing the information and will issue additional updates with further details and tools to help members comply. There are some important implementation dates members need to know. 

These requirements go into effect with the publication in the Federal Register of the  interim final rule  on May 8, 2020. 

CMS had previously communicated the effective date was May 1. However, CMS revised the effective date to be May 8, 2020.  
  • The effective date means nursing homes are required to begin notifications of residents, their representatives and families as of May 8. This means the first notification could be required to occur by May 9 at 5 pm, should the facility have any of the resident and/or staff cases on May 8 as described by CMS required to make notification. 
  • Action: Ensure system and processes for notifications are in place in your facility by May 8 to meet new requirements.  
Facilities must submit their first set of data by 11:59 pm on Sunday, May 17, 2020 to the NHSN Long-Term Care Facility COVID-19 Module.
  • Action: Register now for NHSN and begin collecting data starting May 8, 2020. [NOTE: registration is taking more time than expected and we encourage you to start now to avoid further delays that may impact your compliance.] 
  • The memo provides an overview of the registration process.  
  • For NHSN questions, please email: NHSN@cdc.gov and add “LTCF” in the subject header. 
CMS will provide facilities with an initial two-week grace period to begin reporting cases in the NHSN system (which ends at 11:59 p.m. on May 24, 2020). Facilities that do not begin reporting after the third week (by 11:59 pm on May 31, 2020) will receive a warning letter reminding them to begin reporting the required information to the CDC. 

For facilities that have not started reporting in the NHSN system by 11:59 p.m. on June 7, ending the fourth week of reporting, CMS will impose a per day (PD) CMP of $1,000 for the failure to report that week. 

For each subsequent week that the facility fails to submit the required report, the noncompliance will result in an additional one-day PD CMP imposed at an amount increased by $500. 

For enforcement-related questions, please email:   DNH_Enforcement@cms.hhs.gov

New COVID-19 F-tags & Updated Survey Tools 
CMS has established two new F-Tags - F884: COVID-19 Reporting to CDC and F885 COVID-19 Reporting to Residents, their Representatives, and Families. 

CMS has updated survey tools including COVID-19 Focused Survey for Nursing Homes, Entrance Conference Worksheet, COVID-19 Focused Survey Protocol, and Summary of the COVID-19 Focused Survey for Nursing Homes. These updated forms are posted to the  Survey Resources folder  in the COVID-19 Focused Survey sub-folder on the CMS Nursing Homes website. 
  • Action: Facilities should begin using the revised “COVID-19 Focused Survey for Nursing Homes” to perform their self-assessment. Surveyors will begin using these revised documents immediately.  

Public Posting of NHSN Data Anticipated By End of May 
CMS anticipates publicly posting CDC’s NHSN data (including facility names, number of COVID-19 suspected and confirmed cases, deaths, and other data as determined appropriate) weekly on Monday’s at  https://data.cms.gov/  by the end of May. 

Multiple Q&A 
CMS provides 22 Q&A in the last 7 pages of the memo. Question 10 addresses retrospective reporting and reads as below: 
  • Q: Are facilities required to report data that predates the effective date (May 8) of the interim final rule? 
  • A: No, there is no requirement in the rule to collect older data.  
Battelle Transportation Plan
The Kansas COVID-19 N95 Decontamination System transportation plan is below. Please note, there are multiple transportation options included in this plan. If you have any questions regarding these options, please contact your County Emergency Manager (EM) . 

Has your agency started the Battelle registration but the process has stalled for one of the following reasons:
  1. Filled out the registration form at the link below but never heard back?
  2. https://www.battelle.org/inquiry/offerings-and-services/covid-response
  3. Completed and emailed back the Service Agreement AND then the Site Locations and POC Information form, have waited the requested amount of time and haven’t heard back?
 
If the process has stalled (beyond the timeframe you were told it should take) for either of the above mentioned reasons, please send a note to Seth ( seth.konkel82@gmail.com ) at the State EOC with the following information. 
  • Agency Name
  • Name of person in agency who filled out the form (POC)
  • POC’s phone number
  • POC’s email address
Kansas Health Care Association and the Kansas Center for Assisted Living
1100 SW Gage Blvd Topeka, KS 66604
PH: 785-267-6003 FAX: 785-267-0833