January 18, 2021
WHCA has been notified by a member that as many as five separate commonly-owned buildings have received Department of Health (DOH) inspections in the same week. Citations resulting from the inspections focused on infection control practices and improper use of N95 respirators.

If you have not already implemented a Respiratory Protection Program in your facility, you may be subject to fines from both DOH and L&I’s Division of Occupational Safety and Health (DOSH). Facilities that are not performing proper fit testing procedures located at Appendix A for employees prior to N95 use will be cited. 

You are advised to immediately review the Respiratory Protection Standard. The standard includes requirements for a written program, medical evaluation, and initial fit testing and training for N95 wearers. Employers must comply with the requirements in the standard to ensure workers have and are properly using appropriate respiratory protection when necessary to protect their health. The requirements are outlined in section 1910.134(c). The Occupational Safety and Health Administration (OSHA) has also issued Temporary Enforcement Guidance that explains citation guidelines for state inspectors.

Employer Resources Northwest (ERNwest) has worked to develop a sample Respiratory Protection Program for healthcare facilities that will help guide you through the compliance process. This document provides a template that is free to use for all members of the Washington Health Care Association, and should help you meet the requirements outlined in the Respiratory Protection Standard. This template was modified by staff of ERNwest to comply with Washington State regulations. ERNwest is WHCA’s partner in the WHCA Retro program. 
The Department of Health & Human Services (HHS) launched the Provider Relief Fund (PRF) Reporting Portal. The portal is only open for providers to set up user accounts and register to submit reports. In the updated PRF Reporting requirements, HHS indicates reporting is delayed until further notice. No date is provided in the PRF Reporting FAQs. Highlights from the Reporting FAQs include:
  • Nursing Home Infection Control Reporting – While reporting guidance has not yet been released, providers who received these allocations must register; 
  • Providers may not use their Optum account information, such as Optum ID, to register; 
  • HHS has not set a deadline to register; 
  • Providers submitting multiple reports for multiple subsidiaries must set up unique reporting registrations for each. Conversely, if a provider with multiple subsidiaries is submitting a single report, only one registration is needed; 
  • Parent companies reporting on multiple TINs must include all TINs when registering to report; and 
  • Any updates to registration information only can be made when the reporting web portal goes live. 

You may view the PRF Reporting and Audit webpage with reporting guidance here. AHCA/NCAL has provided a summary of changes to the Post-Payment Notice of PRF Reporting Requirements here. To access AHCA/NCAL’s webinar on reporting requirements and general information, click here. Please note that this webinar does not reflect the January 15, 2021, reporting updates. For AICPA’s webinar on Single Audit (sponsored by the AICPA Governmental Audit Quality Center), click here.
Due to the prolonged COVID-19 challenges throughout Washington State, the Department of Home and Community Services has received approval to extend its surge efforts through January 31, 2021. HCS division is continuing the following activities to assist with transitions from acute hospitals:
  • Overtime: Will continue the use of overtime to assess acute hospital referrals timely and to focus efforts on transition of complex patients to all settings.
  • $60 Specialized Dementia Care Program (SDCP) add on: Re-implemented the $60 rate add on for contracted SDCP facilities accepting individuals out of acute care hospitals as in the first surge, utilizing the same process and criteria.
  • Expanding contracts: Continue resource development efforts to increase specialty contracted Enhanced Adult Residential Care contracted facilities.
  • Transitional Care Center of Seattle (TCCS): Began accepting dually-eligible, Medicare and Medicaid, admissions on December 28, 2020, and will continue to work closely with this facility as it expands capacity to transition patients from acute care hospitals.
  • $100 day SNF incentive: The $6000 SNF incentive for new acute care hospital admissions ended on December 31, 2020. During the month of January, dually- eligible individuals newly admitting to nursing facilities from acute care hospitals will receive a $100 daily add on to the Medicaid nursing facility rate for a period not to exceed six months when:
  • A client-specific approval letter is requested and approved by Home and Community Services prior to admission.
  • The Individual admits on or before January 31, 2021. 
  • The Department receives a Nursing Facility Notice of Action confirming Admission date.
  • The Department has confirmed that this is a new Nursing Facility admission. Readmissions and Nursing Facility transfers are not eligible for this incentive.
  • The department will follow up with a Dear Provider letter specific to this incentive.
COVID+ Units Multiple nursing facilities across the state now have dedicated COVID-19+ units. A current list of contracted facilities can be found via this webpage link (COVID-19+ Unit Nursing Facilities). The department will continue to evaluate the need for additional bed capacity and add nursing facilities as needed. The planned timeframe for these nursing facilities to have dedicated units providing care to COVID-19+ residents is through March 31, 2021, but may be extended depending on need and as funding is available.
MCO Assistance HCA is continuing to request that MCOs pay increased rates to SNFs willing to accept acute hospital patients. If the individual is Medicaid only, MCOs have a responsibility to assist in the transition from acute hospital to a lower level of care. If the lower level of care is a SNF, the MCOs also have a responsibility to assist in the transition from the SNF to another community setting of the individual’s choice.

Nursing facilities and Assisted Living facilities continue to play a critical role in efforts to transition individuals out of acute hospitals. We couldn’t accomplish this work without their willingness and support. Home and Community Services acknowledges this important partnership and looks forward to continued collaboration as we serve our respective communities together. 
As COVID-19 vaccines are rolling out to skilled nursing facilities and assisted living communities across the country, providers are working hard to educate their staff and residents about the safety and benefits of the vaccine. AHCA/NCAL has updated its tactics for effectively communicating with staff to reflect best practices gathered from providers across the country. Providers are encouraged to review this document for tips in promoting vaccine acceptance among both staff and residents. For more resources, check out AHCA/NCAL’s #getvaccinated website.
WHCA continues to post resources and information as it becomes available on our website. If you have questions or need additional information, please call the WHCA office at (800) 562-6170.