Greetings!
This update includes:
- information on how the $20/day Medicaid rate increase will be implemented;
- details on the updates to Five Star, staffing data, and FAQs;
- reminders about continuing restrictions on visitors in LTC;
- an explanation of the formula for distribution of Provider Relief Funds; and
- a link to the updated Medicare billing FAQs.
Sincerely,
April Payne, LNHA
Vice President of Quality Improvement | Director of VCAL
Virginia Health Care Association | Virginia Center for Assisted Living
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Information on Implementation of $20/day Medicaid Add-On
DMAS has finalized the
guidance
and templates (linked below) for the $20 per day add-on. The process is now live. The process is essentially what we described in the
CareConnection on April 23
. There are a couple of important changes relative to previous reporting of the process:
- DMAS is asking that you roster bill the March (12-31) days by Friday May 1 (payment around May 15). If you cannot make it by this Friday, just include them with your April days, submitted by May 8. In all cases, missing deadlines does not preclude you from the reimbursement, it just delays it.
- DMAS is asking that banking information be sent to the MCOs no later than April 29.
- The first payment will likely be through paper check(s) overnighted to the billing entity (subsequent monthly payments should be by EFT within two weeks of submission).
- The FFS address (for FFS roster submissions and for copied MCO submissions) is in the updated table.
- Please make sure you use the FFS template for your FFS submission with the separate tabs to report by hospice provider (separately reporting hospice is not necessary for CCC Plus).
- Do not forget these submissions contain PHI and must be encrypted.
DMAS Guidance and Templates
Please contact
Steve Ford
if you have any questions or issues with the process once you begin submission.
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Five Star Updates, Nursing Home Staff Counts, and FAQs
On April 24, 2020, CMS released a
memo (QSO-20-28-NH)
with updates on Nursing Home Compare (NHC), Five Star, public staffing information, and a list of frequently asked questions (FAQs).
Inspection Domain of Five Star Quality Rating System Will NOT be Updated Due to Prioritization of Surveys
CMS will temporarily hold constant the inspection domain of Five Star to prevent an unequal impact on the rating for those facilities who receive a survey during this time. This freeze will begin with the scheduled Nursing Home Compare update on April 29, 2020.
CMS will post the results of any health inspections conducted on or after March 4, 2020, on the landing page of Nursing Home Compare, but they will not be used to calculate a center’s Five Star inspection rating.
The Quality Measure and Staffing domains of Five Star will be updated on April 29 as they are not impacted by the
CMS blanket waivers
because they rely on data from before March 1, 2020.
Release of Certain Staffing Information
CMS will use Payroll-Based Journal (PBJ) staffing data to publicly report the average number of staff onsite at each nursing home each day (both nursing staff and total staff) and will also post aggregated data at a state and national level. The publicly posted information will include all staff listed in section 2.3, Table 1 of the
PBJ Policy Manual
.
This information will be based on data submitted for the fourth quarter of 2019. CMS states this information can be used to help local, state, and federal agencies’ plan for how much PPE), testing, and other resources providers may need. Providers can also use this information along with the
CDC PPE burn rate calculator
.
CMS FAQs
The memo includes a FAQ document that addresses CMS guidance in the areas of visitation, surveys, waivers, and more. The FAQs provide information on topics including:
- individuals entering and leaving the nursing center, including visits by health care personnel, visitation for compassionate care situations, and residents who want to leave the facility against medical advice;
- surveys and infection control self-assessment, including the ongoing suspension of standard surveys and the recommended use of the infection control focused survey protocol for self-assessment on infection control practices and preparedness;
- waivers of federal requirements including those related to in-facility and inter-facility cohorting; and,
- additional information on resident cohorting, separation, and admission.
CMS reminds providers that a negative test for COVID-19 is not a prerequisite for discharging a resident to a nursing home from the hospital; however, consistent with current guidance, admissions decisions should be made based on the resident’s clinical status and the ability of the accepting facility to meet their care needs and infection control requirements. Providers who cannot meet the needs of the residents due to PPE, staffing, or other issues should not accept the person.
CMS is allowing civil money penalty (CMP) funds to be used for purchasing devices such as tablets or web-cams as well as accessories, with a maximum of $3,000 allowed per facility to help with communications between residents and their families or friends. To apply to receive CMP funds for this purpose, contact your
state agency’s CMP contact
. VHCA-VCAL is exploring these CMP grant opportunities.
Questions
For questions related to the Nursing Home Compare website and the Five Star Quality Rating System, please email
[email protected]
. For questions related to the FAQs, please email
[email protected]
.
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Continuing Restrictions on Visitors in LTC
Even as states are beginning to lift their stay at home orders, nursing homes must continue to maintain current restrictions on visitors. As a reminder,
CMS released guidance
on March 13 that required all nursing homes to significantly restrict visitors and nonessential personnel, as well as restrict communal activities. The guidance indicates that individuals other than essential health care staff and visits for end-of-life situations, should no longer enter nursing homes until further notice.
Even though certain states may be lifting their individual stay-at-home orders, Virginia’s stay-at-home order is in effect until June 10 (unless amended or rescinded.) Nursing homes must continue to follow this directive from CMS until new guidance is received. For help communicating these policies, please see our
sample letter to families on restricting visitors
.
For all long term care communities, these restrictions remain critical safeguards to help protect against the spread of COVID-19.
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Explanation of the HHS Formula for
Distribution of Provider Relief Funds
The US Department of Health and Human Services (HHS) allocated another $20 billion on Friday, April 24, 2020, to all Medicare providers. You may have received a check already and if not, you should over the next week. HHS intends to send checks to Medicaid-only providers but is not doing so in this payment. AHCA continues to work with HHS to develop the system to get those funds distributed.
The notice from HHS is confusing, but here is the explanation. Combined with the $30 billion two weeks ago, with this $20 billion payment, HHS has now paid $50 billion to Medicare providers. Here is the formula:
- Start with $2.5 trillion, which is what they calculate as the spend for all Medicare providers.
- Divide each provider’s revenue by $2.5 trillion to get the percentage attributable to each building.
- Multiply the provider’s percentage by $50 billion (the full amount of payments to all providers) to determine the amount for each provider.
- For the payments going out this week, HHS is then deducting the amount distributed two weeks ago to determine the final payment.
Or:
(
[
Facility's 2018 Net Patient Revenue
÷
$2.5 Trillion
]
X
$50 billion
) -
Amount given in first payment
=
New distribution amount
In addition, HHS paid out another $20 billion from the fund, but it appears that all that money is going to hospitals. While we acknowledge that hospitals need financial assistance, the battle against COVID-19 is being fought in long term and post-acute care facilities. We will be demanding fair treatment for our facilities in upcoming payments.
The good news is that Congress added $75 billion in funds to this HHS effort, so even with these payments, there is over $100 billion left in the Provider Relief Fund. We will do everything possible to get you what you need out of this fund.
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CMS Updates COVID-19 FAQs on Medicare FFS Billing
A general billing requirements FAQ related to using the “DR” condition code and “CR” modifier on claims to indicate that the Medicare payment is conditioned on the presence of a “formal waiver” has been updated and should be reviewed by billing staff.
The SNF-specific FAQs are on pages 34-35 and have not changed since they were last updated on April 10.
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