Greetings!

This message includes: 
  • a link to the phased reopening guidance issued Friday and a request for feedback;
  • what we know about the governor’s announcement about funding for LTC;
  • information on Medicare coverage of COVID-19 testing;
  • details on a N95 Respiratory Fit Testing Train-the-Trainer Course; and
  • HHS updates to the Provider Relief Fund FAQs.
 
As a reminder, we will be holding a member call on Friday, June 26 at 3:30 pm. We anticipate that much of the call will focus on the reopening guidance.

Sincerely,

April Payne, LNHA
Vice President of Quality Improvement | Director of VCAL
Virginia Health Care Association | Virginia Center for Assisted Living 
Phased Reopening Guidance
 
As you review the VDH Nursing Home Guidance for Phased Reopening and have questions or items you believe should be clarified, please email me . We have compiled a detailed list of questions we will be sharing with VDH.

As we mentioned on Friday, we have been assured that this guidance will be dynamic, meaning it will be augmented though FAQs or modified as necessary going forward.

Please note that on June 19 VDH also issued an update to the VDH COVID-19 Interim Guidance for Long-Term Care Facilities. Updates since the last version include:
  • Added section on hand hygiene
  • Added information to further clarify recommendations related to cohorting, PPE use (especially related to gowns), and cleaning and disinfection
  • Revised language to reflect the lifting of restrictions during phased reopening in accordance with the Forward Virginia and the VDH Nursing Home Guidance for Phased Reopening
  • Differentiated nursing home recommendations from those for other LTCFs where applicable
COVID-19 Funding

On the COVID-19 funding, the governor’s press release stated there is $246 million in new funding for nursing and assisted living facilities. It is important to note, the $246 million announced is the total amount of funding that the state and federal government have allocated for Virginia’s nursing and assisted living facilities ($226 million to nursing facilities and $20 million to assisted living facilities).

As you may recall, $152 million was already authorized by the CARES Act distributed through the HHS Provider Relief Fund. The governor‘s announcement on Friday provides a continuation of the $20 per day Medicaid add-on for four months (through October). It is not clear if the four additional months are guaranteed, but that value is approximately $40 million. If you subtract the funding already in place for nursing facilities, the governor has allocated $34 million in new funds. While VHCA-VCAL is awaiting official guidance on how the new nursing and assisted living funding will be accessed, we have been told that nursing facilities would only access it after the direct provider relief (the $152 million) is expended.

In addition to the new nursing center funding, $20 million is provided for Virginia’s assisted living facilities. This is the first direct support provided to Virginia’s assisted living facilities and is very welcome news.
Medicare Coverage of COVID-19 Testing
for Nursing Home Residents and Patients

On June 19 CMS instructed Medicare Administrative Contactors and notified Medicare Advantage plans to cover COVID-19 laboratory tests for nursing home residents and patients. This instruction follows the CDC’s recent update of COVID-19 testing guidelines for nursing homes that provides recommendations for testing of nursing home residents and patients with symptoms consistent with COVID-19 as well as for asymptomatic residents and patients who have been exposed to COVID like in an outbreak. Original Medicare and Medicare Advantage plans will cover COVID-19 lab tests consistent with CDC guidance.

Medicare Advantage plans must continue not to charge cost sharing (including deductibles, copayments, and coinsurance) or apply prior authorization or other utilization management requirements for COVID-19 tests and testing-related services.

Additional information
N95 Respiratory Fit Testing Train-the-Trainer Course

VDH is hosting a series of Respiratory Fit Testing Train-the-Trainer Courses from June 30 – July 29. Space is limited and available on a first-come-first-serve basis.

The Virginia Healthcare Emergency Management Program, in partnership with Russell Phillips & Associates, conducted a statewide assessment of licensed skilled nursing facilities COVID-19 capabilities and needs at the end of May and early June. One of the needs identified in the assessment was fit testing.

Individuals who attend the 2.5 hour course will be able to train others in the proper procedures for fit-testing. This training is for qualitative testing using a hood, and not quantitative testing.

Advance Preparation
 
Everyone who attends the Train-the-Trainer training needs to:
  1. Complete the OSHA Medical Questionnaire.
  2. Secure the signature of a physician or other licensed healthcare professional on the Medical Recommendation for Respirator Use Form and bring it to the training.
  3. Bring a N95 Fit Test Kit like this one and N95 mask with them to the training.

Note 1: If you do not have a N95 respirator fit test kit, email [email protected] stating you do not. We can make arrangements to have one to use during the training.

Note 2: VDH is only doing the initial fit testing, and any further checks/maintenance/documentation etc. are the responsibility of the employer/employee.
HHS Updates Provider Relief Fund FAQs

On June 22, the US Department of Health and Human Services (HHS) made several updates to the Provider Relief Fund FAQs. Additionally, on Thursday, June 25, HHS will be offering webinars on the Medicaid Allocation application process. To register for one of the webinars, click here.

Below is a summary of changes to the FAQs specific to long term care providers.

HHS added detail on calculating lost revenue and revenue (page 7)

“You may use any reasonable method of estimating the revenue during March and April 2020 compared to the same period had COVID-19 not appeared. For example, if you have a budget prepared without taking into account the impact of COVID-19, the estimated lost revenue could be the difference between your budgeted revenue and actual revenue. It would also be reasonable be the difference between your budgeted revenue and actual revenue. It would also be reasonable to compare the revenues to the same period last year.”

On page 38, HHS also notes that patient out-of-pocket costs should be counted as revenue. Later on page 39, HHS indicates that revenue lost under Medicaid value-based purchasing programs may be counted as lost revenue.

Duration of Terms and Conditions (page 9)

“Some Terms and Conditions relate to the provider’s use of the funds, and thus they apply until the provider has exhausted these funds. Other Terms and Conditions apply to a longer time period, for example, regarding maintaining all records pertaining to expenditures under the Provider Relief Fund payment for three years from the date of the final expenditure”.

Change in Ownership Additional Detail (page 9)

HHS elaborates upon scenarios in which sellers may not transfer funds.

Medicaid Allocations (page 38)

HHS notes that even a small General Distribution payment makes a provider ineligible for the Medicaid Allocation. The Department also added detail on who may apply noting that if a provider did not bill Medicaid/CHIP during the eligibility window, providers may apply for Medicaid allocation funding as long as they provided diagnoses, testing, or care for individuals with possible or actual cases of COVID-19 after January 31, 2020 and can produce evidence of such care.

Additionally, HHS limits on page 39 which providers who enrolled as Medicaid/CHIP providers in 2020 may apply. Also, on page 39, the Department notes that providers who bill under Medicaid Managed Care may apply.

Tax Information

On pages 38 and 41, HHS clarifies needed tax documentation information.
Upcoming Events
 
June 25, 2020 | 2:00 pm

July 14, 2020 | 2:00 pm
 
July 23, 2020 | 10:00 am
Quick Links
www.vhca.org | (804) 353-9101 | Calendar of Events