Greetings!
This update covers:
- VDH guidance on PPE optimization strategies in LTC facilities;
- information from OSHA on PPE shortages;
- PBJ submission waiver for Q1;
- info on upcoming CMS calls;
- details about the Payroll Protection Program; and
- info on HUD relief.
We also have another video for you to share with residents and staff. This one is from Rep. Rob Wittman (VA-01).
We will continue to send new information and updates as they become available.
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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Optimization Strategies for PPE in LTC Facilities
The guidance includes specific strategies for the following types of PPE in case of shortage, or unavailability:
- Respirator
- Facemask
- Gown
- Eye protection/face shield
The strategies can be adapted for the clinical management of COVID-19 cases in LTCFs.
The guidance notes, because this is a rapidly evolving situation and recommendations might change as we learn more about the virus causing COVID-19, it is advised to continuously check the following links for CDC updates:
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OSHA Issues Memoranda on Respiratory Protection
The Occupational Safety and Health Administration (OSHA) has issued two separate enforcement memoranda related to the use of respirators by healthcare and non-healthcare employers. This includes all long term care providers: skilled nursing, assisted living, and ID/DD providers. The memoranda address issues facing employers regarding the respirator shortage, giving employers limited relief from OSHA’s Respiratory Protection standard as a result from COVID-19.
Be Prepared: OSHA Requirements for PPE
AHCA/NCAL has learned that some members and other health care entities are receiving letters from OSHA regarding lack of PPE. AHCA/NCAL has consulted with our outside consultants who recommend preparing a plan with the following information:
- If you are running low on PPE, follow the CDC guidance and guidance from your local health department.
- Have a plan in place that deals with potential exposure to COVID-19 for employees, for example, what happens if a staff member has respiratory or other symptoms indicative of COVID-19 or tests positive with COVID-19.
- Communicate this plan to all staff often and have it available for staff to review.
Recording Workplace Exposures to COVID-19
OSHA recordkeeping requirements at
29 CFR Part 1904
mandate covered employers record certain work-related injuries and illnesses on their OSHA 300 log. While these requirements exempt recording of the common cold or flu, COVID-19 is a recordable illness when a worker is infected on the job if the following are met:
- Case is confirmed COVID-19;
- The case is work-related as defined by 29 CFR 1904.5; and
- The case involves one or more of the general recording criteria set forth in 29 CFR 1904.7.
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Payroll Based Journal Update
CMS is waiving 42 CFR 483.70(q) to provide relief to long term care facilities on the requirements for submitting staffing data through the Payroll-Based Journal system. This means that staffing data for the first quarter of 2020 (1/1/20 – 3/31/20) will not need to be submitted for the May 15, 2020 deadline, nor will this data need to be submitted later.
At present, there is no additional information as to how long this waiver will remain in place and
providers should continue to collect staffing data
, as CMS has only waived submission of data but not the collection of the data.
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CMS Calls Later Today and Thursday
COVID-19 with Nursing Homes
CMS leadership will provide updates on the agency’s latest guidance and will be joined by leaders in the field interested in sharing best practices with their peers. The call will be recorded. Conference lines are limited, so CMS is recommending participation via
audio webcast
, either on your computer or smartphone web browser.
April 8, 2020 | 4:30 – 5:00 pm
Attendee Dial-In: (833) 614-0820
Conference ID: 6798274
CMS “Office Hours” on COVID-19
CMS is hosting opportunities for hospitals, health systems, and providers to ask questions of agency officials regarding CMS’s temporary actions that empower local hospitals and healthcare systems to:
- increase hospital capacity;
- rapidly expand the healthcare workforce;
- put patients over paperwork; and
- further promote telehealth in Medicare.
April 9, 2020 | 5:00 – 6:00 pm
Attendee Dial In: (833) 614-0820
Event Plus Passcode: 1881716
Conference lines are limited, so CMS highly encourages you to join via audio webcast, either on your computer or smartphone web browser.
You can submit questions in advance to
[email protected], including “Office Hours” in the subject line. There will also be live Q&A.
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FAQs on the Payroll Protection Program
The US Department of the Treasury released a new
Paycheck Protection Program (PPP) Loans FAQ
dated April 8 that clarifies certain areas of the program created by the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). Among other topics, the FAQ specifies that the $100,000 cap on payroll costs used to calculate the PPP loan size applies to
salary costs
only. This means that a wider range of employees can be factored into the loan size calculation than originally believed, since healthcare benefits, retirement benefits and other compensation do not need to be factored into the cap.
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HUD COVID-19 Relief
AHCA/NCAL has received confirmation from the US Department of Housing and Urban Development (HUD) that in response to recommendations from the industry, HUD review and approval of the below types of transactions for Section 232 insured facilities impacted by COVID-19 is not required. If the lender has been notified that the project is with the Risk Mitigation Branch, then HUD approval is required. This is effective through July 31, 2020 and applies to the following:
- Suspend monthly deposits to the replacement reserve through July 31, 2020, at which time the deposits will resume unless HUD grants a further extension. At the conclusion of the suspension period, the sum of the suspended payments shall be paid into the Reserves for Replacement in equal monthly increments over the next 12 consecutive months.
- Use operating deficit funds to meet debt service payments, subject to repayment provisions, if any, contained in the subject escrow agreement.
- Use debt service reserves to meet debt service payments; subject to repayment provisions, if any, contained in the subject escrow agreement.
- Use replacement reserve accounts to meet debt service payment requirements so long as the account balance does not fall below $1,000 per unit.
To exercise this authority, borrowers must demonstrate, to the lender’s satisfaction, that their request results from the impacts of COVID-19. While HUD approval will not be required, the lender is expected to report any utilization of the above to their assigned account executive and discuss any new risks at the facility that have may have emerged.
On a case-by-case basis, HUD will consider requests from borrowers for other non-conventional uses of escrow funds. Balances in these accounts are typically not significantly larger than the projected amounts needed for those accounts’ intended purposes. Moreover, the balances are not likely substantial enough to significantly offset COVID-19 operating revenue and expense impacts.
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Rep. Rob Wittman's Message to Residents and Staff
Rep. Rob Wittman (VA-01) recorded a special message for us to share with you. The congresman offers his profound thanks to residents and staff for their efforts to deal with this health emergency.
We encourage you to show it to your residents and staff and share it on your social media channels.
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