COVID-19 UPDATE #33
May 19, 2020
CMS ISSUES NURSING HOME REOPENING RECOMMENDATIONS FOR STATE AND LOCAL OFFICIALS
On May 18, CMS provided recommendations on a nursing home phased reopening for states. The recommendations cover the following items: 
  • Recommendations for testing residents and staff 
  • Dedicated space for cohorting residents with COVID-19 
  • Criteria for relaxing certain restrictions and mitigating the risk of resurgence 
  • Visitation and service considerations 
  • Restoration of survey activities 

The guidance encourages state leaders to collaborate with the state survey agency and local health departments to decide how these criteria should be implemented. Given the critical importance in limiting COVID-19 exposure in nursing homes, CMS recommends that decisions on relaxing restrictions be made with careful review of the following facility-level, community, and state factors: 
  • Baseline test of all residents, weekly testing of all staff, practicing social distancing, and universal source control for residents and visitors (e.g., face coverings) 
  • Status of COVID-19 cases in the local community 
  • Status of COVID-19 cases in nursing homes 
  • Adequate staffing 
  • Access to adequate personal protective equipment (PPE) 
  • Local hospital capacity 

The American Health Care Association and National Center for Assisted Living will provide a detailed analysis soon. You can read the press release , guidance , and FAQs from CMS.
WHCA ENGAGES IN CONVERSATIONS REGARDING WASHINGTON'S TRANSITION PLAN FOR ALL LTC CENTERS
WHCA is working fast and furiously with LeadingAge Washington, the Adult Family Home Council, state agencies, and the Governor’s office to seek guidance, provide feedback, and advocate for our members regarding the state’s LTC transition plan. This includes issues such as testing for staff/residents, PPE, visitation, dining, and activities. While CMS issued the QSO memo for state authorities related to nursing homes/skilled nursing facilities, exactly how this will be implemented remains to be seen. Also, the plan for other LTC settings such as assisted living and adult family homes is currently undergoing active discussion. As more information is obtained, WHCA will promptly inform our members. If you have questions, please email Elena Madrid or Vicki McNealley .
SKILLED NURSING RESOURCES FOR ASSISTED LIVING FACILITIES WITH COVID-19 RESIDENTS
The long term care community has been the most impacted by the COVID-19 pandemic. Skilled nursing facilities have not been the only entity hit hard as news of outbreaks at assisted living facilities is being reported. Often times, residents who test positive and seek treatment in the hospital setting are unable to return to the assisted living facility following hospitalization due to lack of PPE, inability to effectively isolate the resident, or staffing issues.
 
Avamere Family of Companies has established COVID-19 units in Bellingham, Shoreline and Tacoma. Avalon Health and Rehab in Pasco has also developed a COVID-19 unit. These units were created to help hospitals' capacity, support the healthcare community and provide care to those recovering from COVID-19.
 
Assisted living facilities that have experienced outbreaks can refer their residents to these COVID-19 units if circumstances create difficulty in treating the resident(s) in-house. Individuals requiring short-term or COVID-19 specific care while waiting to return to their residence are appropriate. Bed availability is limited and admissions are reviewed and accepted on a case-by-case basis. To initiate a referral please contact your nearest building below:
PHASE 2 ALLOWANCES ARE NOT THE SAME FOR LONG TERM CARE CENTERS
As Governor Inslee moves toward Phase 2 of the state’s plan to reopen Washington, it is important to note that long term care facilities, including assisted living, are not included within that phase. Hair salons, nail salons, spas, and other outside companies that operate within the walls of a long term care facility cannot reopen during Phase 2. WHCA is working closely with the Governor’s office and the state Department of Health to determine safe and reasonable methods to gradually loosen the limitations on long term care facilities, including communal dining, group activities, and visitation as well as outside company operations within the facility.
REIMBURSEMENT AND LEGAL ISSUES RELATED TO
COVID-19 TESTING IN LONG TERM CARE
We have received many questions from members on reimbursement and legal issues related to COVID-19 testing in LTC. Responses to common member questions are included below:

Reimbursement Issues
Medicare Coverage of Testing: Medicare fee for service and Medicare Advantage plans will cover the cost of COVID-19 diagnostic (PCR) tests. Tests range in cost from $115 to $500. Medicare Part B will only reimburse approximate $100 for the PCR and $35 for other tests. However, not all labs will bill Medicare directly. AHCA/NCAL strongly recommends that, wherever possible, providers use labs that will bill Medicare, as providers may not be able to bill for these services.

CARES Act Coverage: The CARES Act requires health plans to cover the cost of COVID-19 testing for beneficiaries at no cost to the beneficiary. CMS is requiring Medicare Advantage Plans to cover the costs of testing for MA plan beneficiaries. Typically, however, when a test is required by an employer for employment, then the employer is responsible for the cost of the test. If the state is mandating testing, the employer may not be held accountable for the cost of the test but this has not yet been validated.

CARES Act Grant Funds: The CARES Act Grant Funds can be used to cover costs for resident tests that are not otherwise reimbursable. This does NOT include testing for residents under a Part A stay where it is included in consolidated billing.

Legal Issues
Resident Refusals: Residents that refuse to be tested for COVID-19 cannot be discharged involuntarily, unless the facility is otherwise incapable of caring for residents with a confirmed diagnosis of COVID-19.

Employee Refusals: Employers can make COVID-19 testing a condition of employment and terminate or not hire a person who refuses to obtain a COVID-19 test.

For more information, please review the reimbursement and legal section of AHCA/NCAL’s Preparing for Widespread Testing in LTC Guidance .
INFECTION PREVENTION CONTROL OFFICER VERSION 2 TRAINING NOW AVAILABLE WITH BONUS COVID-19 CONTENT
The emergence of COVID-19 has compounded the need for centers to have an effective infection prevention and control program. AHCA/NCAL’s new and expanded version of its popular Infection Preventionist Specialized Training, IPCO Version 2  is now available. The online training is recommended for individuals responsible for infection prevention and control in all long term care settings, including assisted living communities.

IPCO Version 2 is designed to train the Infection Preventionists to run a comprehensive infection prevention and control program. It is also now available for administrators to take to gain a deeper understanding of the infection prevention and control in the overall operation of a nursing facility. AHCA/NCAL recommends that each skilled nursing facility train at least two Infection Preventionists through AHCA/NCAL’s IPCO training program to ensure appropriate staffing in the event one Infection Preventionist leave the facility. The training is also highly recommended for assisted living communities because they care for a similar population and can face similar infection risks.

As an added feature to all participants registered for the IPCO Version 2 program, bonus content related to COVID-19 is included. The bonus content includes the topics of Interim COVID-19 Guidance, courses on PPE, and N-95 mask use.

Members will need to log in with their AHCA/NCAL usernames and passwords to register for IPCO Version 2. For assistance obtaining AHCA/NCAL usernames and passwords, members should e-mail educate@ahca.org with their name and facility contact information.
US DEPARTMENT OF LABOR ISSUES ALERT TO KEEP NURSING HOME AND LTC FACILITY WORKERS SAFE DURING CORONAVIRUS PANDEMIC
The US Department of Labor's (DOL) Occupational Safety and Health Administration (OSHA) issued an alert on May 14, 2020, listing safety tips employers can follow to help protect nursing home and long term care facility workers from exposure to the coronavirus. The alert is available to download in English and Spanish. The alert also includes OSHA's Guidance on Preparing Workplaces for COVID-19 , a document aimed at helping workers and employers learn about ways to protect themselves and their workplaces during the ongoing pandemic. These OSHA guidelines apply to all places of employment, not just long term care centers. If more restrictive guidelines are in place from state or federal authorities, assisted living and skilled nursing centers must defer to their most regulatory authority, i.e. visitation policy/restrictions.  If you have questions or would like additional information, please contact the WHCA office at (800) 562-6170.
WA-PALTC TO HOST WEBINAR ON TELEHEALTH
The Washington Society of Post-Acute and Long Term Care Medicine is presenting a webinar titled Telehealth in PA/LTC : Can we do better? CMS has loosened restrictions on telehealth in post-acute care centers in the wake of COVID-19. Telehealth has become an important tool, yet many of us are still quite unfamiliar with how to use this tool most effectively. Join this moderated discussion with experts on the changed regulations, billing, and best clinical practices around telehealth. Join the webinar on May 20, 2020, at 6 PM. Register here
DOH TO HOST WEBINAR FOR HEALTHCARE PROVIDERS
The Department of Health will host its weekly webinar on Thursday, May 21, at 11:00 AM. This weekly call is designed for healthcare providers enabling them access to DOH officials and experts so they can get answers to questions and additional information to help them respond to the COVID-19 public health emergency. Register in advance , and once you register, you can save the link to join each week through May 28 as an appointment on your calendar so you will not need to search for the link each week. The password will be provided upon registration. 
ADDITIONAL RESOURCES
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.