Greetings!

This update includes:
  • a link to the Timeline for COVID-19 Regulations and Guidance - May 11, 2020 REVISION;
  • information on how to accurately report staffing and PPE shortages to National Healthcare Safety Network (NHSN);
  • what we know about the statement from the White House about testing for nursing home residents and staff;
  • an op/ed by Keith Hare and his colleagues at LeadingAge Virginia and the Virginia Assisted Living Association, which ran in the Richmond Times-Dispatch this weekend; and
  • information on CMS’s plans to fix PDPM variable per diem glitch and the removal of many Part B therapy code edits.

Sincerely,

April Payne, LNHA
Vice President of Quality Improvement | Director of VCAL
Virginia Health Care Association | Virginia Center for Assisted Living 
NHSN COVID-19 Reporting:
Accurately Reporting Staffing and PPE Shortages

NHSN COVID-19 mandated reporting for nursing homes has begun. AHCA recommends accurately reporting the staffing and PPE situation at nursing homes based on normal standards and guidance for PPE and staffing, not conservation guidance. Federal and state governments will use this data to hold nursing homes accountable for care and services provided and to identify who needs additional resources . It is important that the data reported to NHSN gives an accurate picture of staffing and PPE as well as the other areas collected in NHSN.
 
Given the instructions on NHSN, reporting that you have what you need, tells CMS that you have enough PPE and staff to follow conventional and normal practices, which will likely be used by surveyors when comparing what they find during their surveys. Please use the below guidelines.
 
Staffing
 
NHSN asks “Does your organization have a shortage of staff and/or personnel?” Answer YES if any of the following are occurring during the time period of reporting:
  • Staffing less than your facility needs or internal policies for staffing ratios prior to COVID or based on increased needs since COVID
  • Employing contingency or crisis strategies for staffing shortage
  • Using more agency staff than you used before the pandemic
  • Using volunteers for staffing needs more than what you may have used prior to the pandemic
  • Using any temporary positions per waiver allowances (such as temporary nurse aide or temporary feeding assistant)

PPE
 
NHSN asks “Do you have enough for one week?” each for N95 masks, surgical masks, eye protection, gowns, gloves, alcohol-based hand sanitizer. Answer NO if any of the following are occurring during the time period of reporting:
  • Employing any conservation strategies for PPE use; if you are not able to use PPE per conventional transmission-based precautions in place before the pandemic you should answer NO
  • Using alternative PPE such as cloth masks or other types of face coverings, clothing or other types of coverings instead of surgical gowns, or glasses for eye protection
  • Reusing any single use supply item such as gown or masks
  • If additional residents in the next week will need to be placed on precautions, it will compromise your PPE supply
  • If additional staff in the next week will need to use PPE when returning to work, it will compromise your PPE supply
  • If visitors or contractors in the next week need to visit, it will compromise your PPE supply 
 
As a reminder, nursing homes should keep documentation of their efforts to secure more PPE as well as staffing . You should report to your local and state health departments that you are employing contingency and crisis strategies to conserve PPE and staffing.
White House Tells States to Test
All Nursing Home Residents and Staff
 
Yesterday, the White House recommended to state governors to test all residents and staff in nursing homes across the country within the next two weeks. This is not an order from the federal government and as of May 12 no specific written recommendation has been made. However, we expect to see states develop plans to put these recommendations into place to the extent feasible. Members should review AHCA/NCAL’s Preparing for Widespread Testing in Long Term Care guidance .
 
Providers should prepare to meet this requirement by contacting their state health department to seek information on preferred vendors, testing protocols, availability of tests and reimbursement for testing. You should also ask the state health department what to do and document if a resident or staff person refuses to be tested. Document all your communications with the state health department and the steps you take as a result.
 
In absence of direction from the state health department, facilities can refer to AHCA/NCAL’s list of vendors who can provide testing in the long term care setting. This list is continually updated as new vendors and testing opportunities are available, so please check back frequently.
 
When testing residents and staff, providers must use PCR tests and should not use antibody tests in place of PCR tests unless instructed by your state officials. Antigen tests are new to the market and while we believe they can be used to comply with this new guidance, their availability is still very limited.
 
Residents who test positive for COVID-19 must be isolated and wear a source control mask until placed in isolation. Providers are encouraged to follow AHCA/NCAL guidance on steps to take when COVID-19 gets in . Providers should also explore cohorting with other positive residents, if possible.
 
Providers should review the CDC Return to Work Criteria guidance for considerations for permitting health care providers to return to work without meeting all return to work criteria outlined. In addition, providers should refer to CDC’s Strategies to Mitigate Healthcare Personnel Staffing Shortages for information on contingency and crisis strategies should a large number of your staff test positive.
 
AHCA/NCAL is also seeking feedback from members on COVID-19 test availability and use in both skilled nursing and assisted living settings. Information from this survey will help identify challenges and advocate for more availability and clearer guidance on how testing should be used and reimbursed on a national level.
 
Please take a few minutes to complete the survey by Wednesday, May 13 at 11:59 pm.
  Keith Hare’s Op/Ed on What LTC Facilities Need to
Fight COVID-19

The following column ran in the May 10 edition of the Richmond Times-Dispatch . Please share on your social media channels.
 
Long term care facilities are filled with love and dedication. Here's what else we need.
By Keith Hare, Melissa Andrews and Judy Hackler
 
112. In today’s news reports, if you saw the number 112 and the words long term care or nursing home in the same headline, you might make the leap that it’s a count of seniors stricken with COVID-19, or worse yet, a death toll.
 
However, 112 means something much more to Avicia Thorpe, a Virginia nursing home resident. It’s the milestone birthday she hit this month. Her caregivers helped throw a Zoom party for her and arranged for the local police, fire and rescue squads to sing “Happy Birthday” from outside.

Each day, journalists share heartbreaking scenes in nursing homes and assisted living communities as the coronavirus spreads. We will never get used to seeing families conversing through windows with relatives who are unable to receive visitors during this time, or the idea of final farewells exchanged via FaceTime.
 
Each COVID-19 case and each elder included in statistics on the Virginia Department of Health website represents a treasured person. Victims of this insidious virus were husbands and wives, veterans, teachers, church choir members and avid sports fans. They were beloved family patriarchs or matriarchs who nurtured children and grandchildren. Tragically, their age and underlying health conditions also made them more susceptible to contract COVID-19 and to develop serious — sometimes deadly — complications.
 
We grieve for every individual who has succumbed to this deadly virus, but especially for long term care residents.
 
So do the dedicated caregivers who work inside Virginia’s nursing homes and assisted living facilities. These nurses, aides, housekeepers, cooks and others don’t appear on camera or in newspapers. But they are heartbroken. They grieve every time this virus takes away someone whom they have served, and to whom they have grown close, over many years.
 
These caregivers come to work every day, when staying at home would be so much safer. They put their lives and families at risk because they love their work. They feel called to help residents so they can continue living meaningful lives long after this pandemic becomes a distant memory.
 
Knowing their dedication, it is disappointing to see some place blame on America’s nursing homes and assisted living facilities for deaths from the coronavirus. That blame is misplaced and unfair.
 
There are many reasons why COVID-19 spreads so quickly within nursing homes. By design, these care settings are home to a concentration of older adults with serious underlying health conditions who live in a communal environment and require hands-on assistance with basic daily living activities like dressing and bathing. Although assisted living communities are not medical facilities and serve seniors who don’t require continuous nursing care, their residents do receive daily personal and health care services.
 
This combination of factors helps the coronavirus spread and makes the virus extremely challenging to control, even for facilities that have honed their infection-control and prevention protocols.
As long term care providers, we face additional challenges that are out of our control:
  • We need more personal protective equipment (PPE) — including masks, gowns and gloves — to keep caregivers and residents safe;
  • We need more critical testing tools to help identify and isolate staff and residents who have been exposed to the virus;
  • We need more government funding to cover the true cost of the care we provide;
  • We need more understanding and support.
 
While we are grateful for the creation of the COVID-19 Long Term Care Task Force and a $20 per patient per day increase in funding for nursing facility care provided by Gov. Ralph Northam and the General Assembly, our resource needs at nursing facilities still are significant.
 
Since Virginia’s Medicaid program does not cover assisted living care, those residents and providers are left to bear the costs of battling COVID-19 on their own. Having the necessary PPE to keep residents and staff safe, as well as access to testing to quickly identify and respond to cases, will enable us to save lives. Despite these challenges, residents and staff members are recovering, and it is our hope we can do more.
 
This crisis is not going away soon. Federal, state and local governments must continue to take aggressive actions to work with long term care providers to protect and care for residents and patients. Our vulnerable residents and caregivers on the front lines deserve no less.
 
It’s time to think beyond the statistics. It’s time to rally around our vulnerable residents and provide our long term caregivers all the support they need to stop the spread of COVID-19.
 
(Melissa Andrews is president and CEO of LeadingAge Virginia. Judy Hackler is executive director of the Virginia Assisted Living Association.)
CMS to Fix PDPM Variable Per Diem Glitch

SNF PPS Part A claims were not being paid day-1 variable per diem rates when a beneficiary switched from Medicare Advantage (MA) to fee-for-service Medicare Part A during a stay. AHCA reported to CMS that this was inconsistent with current policy.
 
CMS agreed with AHCA and on May 8 published a change request to the Medicare Administrative Contractors (MACs) to update the claims processing systems retroactive to October 1, 2019. A summary of the changes is posted in this MLN Matters article . Although this is retroactive, the systems changes will not occur until October 5, 2020.
 
Providers should notify billing staff that the MACs will adjust any improperly adjusted SNF PPS claims related to a beneficiary switch from MA to fee-for-service during a stay only if brought to their attention , so that the prior days count is corrected to exclude the MA days. 
Many Part B Therapy Code Edits Removed
 
As part of a recent COVID-19 related update to National Correct Coding Initiative (CCI) files, CMS announced the removal of many problematic claim coding edits related to Medicare Part B PT, OT, and SLP services. The changes are effective for dates of service beginning April 1, 2020. Medicaid and most private insurance also follow the CCI edit policies. Provider billing staff should review the updated files available on the PTP Coding Edit webpage and the Quarterly PTP and MUE Version Update Changes webpage .
Quick Links
www.vhca.org | (804) 353-9101 | Calendar of Events