Greetings!
This message includes:
- a new resource we have created in collaboration with Chiles Healthcare Consulting to provide references to the regulatory and guidance documents issued related to COVID-19;
- clarifications on issues related to the Medicaid $20 per day add-on;
- updated CDC guidance on return to work and clinical care;
- an update on FEMA’s shipments of PPE to nursing homes; and
- CMS claim guidance related to new COVID-19 ICD-10 code.
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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Timeline for COVID-19 Regulations and Guidance
VHCA-VCAL has collaborated with
Chiles Healthcare Consulting to develop a
Timeline for COVID-19 Regulations and Guidance--a chronological timeline that compiles explanations and links for regulations, guidelines, and documents issued throughout the COVID-19 pandemic. It contains references to various federal and state entities that are involved in directing long term care facilities during the pandemic.
The timeline is divided into two sections. The first section is a chronological listing of references, regulations, and guidance offered from federal and state entities. The second section, beginning on page 37, is a chronological listing of waiver and executive orders. The two sections include the date on which the action or notice was published, the topic, a brief summary, and a link to the document referenced. For ease of sorting and recognition, the topics are color coded throughout the document. Please note, this guideline is to be considered a reference tool and should not be considered all-inclusive of guidance and regulations offered during the pandemic.
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Medicaid $20/Day Add-On Clarifications
DMAS has provided guidance on some of the unanswered questions with the $20 per day add-on:
- Specialized Care: If you are a specialized care provider, you should submit separate spreadsheet(s), not a tab in the same sheet, for your specialized care days for FFS and each MCO. Make sure you use the appropriate NPI on the sheet. If you included the specialized care days combined with NF days for the March period do not worry about it, but please use this new approach for April rosters going forward. DMAS states that the MCOs will be made aware of the procedure with specialized care.
- Hospice: DMAS advises that NFs should not bill FFS hospices for the FFS $20 add-on—only do your normal rate billing. DMAS indicates that the hospices will be given a payment schedule to provide the $20 per day add-on to the NFs outside of the normal NF to hospice billing. DMAS does not have specifics on when to expect the hospices to provide the payment, but it should be one to two weeks after the hospices receive the payment form DMAS. None of this matters for the MCO roster billing, which should include hospice days on the same tab as NF days.
- PACE: Days for individuals residing in NFs who participate in the PACE program are eligible for the $20 per day add-on. DMAS has stated that the NF should create a “PACE” tab or tabs on the FFS roster template using a hospice tab as the model (this is not relevant to the MCO template as you cannot be in PACE if you are in CCC Plus). DMAS indicates that they are still working out the details on payments for the PACE days, but this is how the days should be submitted. At this time, it is not clear when and from whom (the PACE or DMAS) payment will be received.
DMAS Templates
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Updated CDC Guidance Released on
Return to Work and Clinical Care
The CDC released two updated guidances on April 30, 2020, around criteria for returning to work for healthcare personnel (HCP) with confirmed or suspected COVID-19 and the discontinuation of transmission-based precautions and disposition of patients with COVID-19.
Decisions about return to work for HCP with confirmed or suspected COVID-19 should be made in the context of local circumstances. This updated guidance includes the following:
- Changed the name of the ‘non-test-based strategy’ to the ‘symptom-based strategy’ for those with symptoms and the ‘time-based strategy’ for those without symptoms
- Updated these to extend the duration of exclusion from work to at least 10 days since symptoms first appeared.
The CDC specifically notes that after returning to work, HCP should:
- Wear a facemask for source control at all times while in the healthcare facility until all symptoms are completely resolved or at baseline. After this time period, these HCP should revert to their facility policy regarding universal source control during the pandemic.
- Self-monitor for symptoms, and seek re-evaluation from occupational health if respiratory symptoms recur or worsen.
CDC also has
information focused around strategies to mitigate healthcare personnel staffing shortages.
This updated guidance includes the following:
- Changed the name of the ‘non-test-based strategy’ to the ‘symptom-based strategy’ for those with symptoms and the ‘time-based strategy’ for those without symptoms, and updated these to extend the duration of Transmission-Based Precautions to at least 10 days since symptoms first appeared.
- Added criteria for discontinuing Transmission-Based Precautions for patients who have laboratory-confirmed COVID-19 but have not had any symptoms of COVID-19.
According to the CDC, if a patient is discharged to a nursing home or other long term care facility (e.g., assisted living community),
and transmission-based precautions:
- are still required, they should go to a facility with an ability to adhere to infection prevention and control recommendations for the care of COVID-19 patients. Preferably, the patient would be placed in a location designated to care for COVID-19 residents.
- have been discontinued, but the patient has persistent symptoms from COVID-19 (e.g., persistent cough), they should be placed in a single room, be restricted to their room to the extent possible, and wear a facemask (if tolerated) during care activities until all symptoms are completely resolved or at baseline.
- have been discontinued and the patient’s symptoms have resolved, they do not require further restrictions, based upon their history of COVID-19.
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Update on FEMA PPE Supply to Nursing Homes
FEMA will coordinate two shipments totaling a 14-day supply of personal protective equipment (PPE) to nursing homes across the nation.
By the beginning of July, each center will receive two separate packages containing a seven-day supply of eye protection, surgical masks, gowns, and gloves. Each center will receive an allotment of all four items based on the staff size of the facility.
The Level 1 medical gowns included in the shipments are intended for use in basic care settings for minimal risk situations. The gowns are durable and can be washed 30 to 50 times.
Due to the large number of nursing homes, centers are not likely to receive notification prior to their shipment arriving. However, as possible, FEMA will provide notification to a state prior to shipments arriving at their Medicaid/Medicare-certified facilities.
The first shipments will begin this week and will continue throughout May. Initial shipments will focus on metropolitan-area priority sites, such as New York City, Northern New Jersey, Boston, Chicago and Washington, DC. The second shipment of supplies will start at the beginning of June. We will continue to share more information as it becomes available.
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CMS Issues Claims Processing Guidance
Related to New COVID-19 ICD-10 Code
AHCA reported to CMS an apparent glitch with implementing the U07.1 - 2019-nCoV acute respiratory disease ICD-10 CM code when the five-day assessment window overlaps March into April dates of service.
For example, when the MDS assessment reference date (ARD) is in April [4/1/20], but the date of service (DOS) is in March [3/25-3/31]. This is creating a problem given the U07.1 code is valid as primary in the MDS grouper April 1 but not on the UB-04 for DOS prior to April 1. Specifically, this is creating a primary diagnosis conflict whereby providers cannot match the primary diagnosis on the UB-04 in form locator 67 with the primary reason for skilled care in item I0020B of the MDS.
CMS has provided the following standardized guidance to the MACs:
“Based on the following guidance from the
CMS PDPM FAQs question 1.8 is to tell providers with a 5-Day PPS MDS with an April 2020 ARD, but a lookback period that extends into March 2020 that, when applicable, they can use the COVID-19 ICD-10 code U07.1 in MDS item I0020B to obtain the appropriate PDPM case-mix classification, but that the claim associated with March DOS must contain a different ICD-10 code that applies to the beneficiary and that was valid in March.
“We understand that this is a one-time event that only impacts a relatively small number of admissions related to COVID-19 that spanned the March-April implementation of the new U07.1 diagnosis code. The claim will need to contain a different diagnosis other than U07.1 but the assessment may contain U07.1 code in these instances.”
We recommend the above be shared with your billing staff.
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