COVID-19 UPDATE #62
July 30, 2020
SENIOR LIVING TRADE ASSOCIATION PORTAL LIVE AND ACCEPTING ASSISTED LIVING PROVIDER INFORMATION FOR POSSIBLE HHS FUNDING
As we shared earlier this week, the U.S. Department of Health and Human Services (HHS) is considering a possible distribution of CARES Act Provider Relief Funds to private-pay assisted living/memory care providers that are stand-alone or part of a CCRC, located in the U.S states and territories. Argentum, ASHA, NCAL, and LeadingAge are assisting HHS in an effort to collect the necessary information from these providers through a private, secure data collection portal to help ease a potential future distribution of application funds. For additional assistance with the portal you can find the FAQ document here. At this time, we have no guarantee such a distribution will happen, nor are we aware of an allocation methodology, if such a distribution were to occur. However, providing HHS with this data is an important step forward, and we appreciate your help in being responsive to their request. Providers should submit the relevant data into this portal by Monday, August 3, at 5:00 pm ET.  
 
Who is eligible to submit information?
We encourage private-pay assisted living and memory care providers that are stand-alone or those that are part of a CCRC in the U.S. states and territories to submit their data. For purposes of this portal, the term licensure also includes assisted living and memory care communities registered or certified by the state. Submitting your data does not guarantee you will receive or be eligible to receive a payment. 

What data must be submitted?
  • Name of licensed/registered/certified assisted living and/or memory care community
  • Name of entity that holds the license/registration/certification
  • Address
  • Community license/registration/certification number (some states may not provide a number)
  • Corresponding Tax Identification Number (TIN)
  • Taxpayer ID Number for the filing company
  • Contact information for the person submitting data
  • Include licensed assisted living that is part of a CCRC or a skilled nursing facility (SNF), even if the SNF has already received funding from the Provider Relief Fund. 

Where do I submit the data?
All of the above information should be submitted either manually or by uploading a specific file ( see instructions for details) in the secure data collection portal. You will need to create an account. Please complete all the fields to ensure your submission will be accepted. Incomplete submissions will likely result in a delay in their inclusion. FAQs are attached, as well, which will be available on the portal soon.
 
What is the deadline to submit data?
Please submit the requested data into the secure data collection portal by Monday, August 3, at 5:00 pm ET
 
Thank you for your quick action in support of this vital aid to our industry.
POTENTIAL RELIEF FOR SNFs WITH A CHOW  
Earlier Changes in Ownership (CHOWs) impeded receipt of Provider Relief Funds for a number of SNFs. In discussions with HHS officials, AHCA/NCAL learned potential fraud is the key concern and this has served as the roadblock. AHCA/NCAL would like to assist by serving as a conduit of CHOW information to attempt to appease the fraud concerns of HHS. It is hoped that by AHCA/NCAL providing data from members about their recent CHOWs, HHS will be willing to provide funding to the appropriate entities. 
 
In order to make this as simple as possible, impacted SNFs are asked to send two pieces of information to AHCA/NCAL at CHOW@ahca.org:  
  1. Medicare Provider Enrollment Form (form CMS 855a) for the CHOW; and 
  2. A brief explanation of the Provider Relief Fund situation – such as “Funds sent to previous owner and have seen been returned to CMS.” 
 
If the CMS 855a form was completed through the electronic provider enrollment web portal, Medicare Provider Enrollment, Chain, and Ownership System ( PECOS), you are asked to provide the information using this spreadsheet format. This should also be sent to CHOW@ahca.org
 
Any questions or concerns should be addressed to the special email account we have created for this effort, CHOW@ahca.org.  
GOVERNOR INSLEE ANNOUNCES EXTENSION OF PROCLAMATION PROTECTING HIGH-RISK EMPLOYEES AND WORKERS’ RIGHTS
As a result of new CDC guidance regarding people at increased risk for severe illness, the extension will provide a clarifying guidance memo. The guidance memo confirms that employees who are 65 and older continue to be covered by the proclamation and clarifies processes for employers of individuals with certain medical conditions.

The proclamation will remain in effect through the duration of the state of emergency, or until otherwise rescinded or amended.
FOURTEEN WASHINGTON FACILITIES TO RECEIVE RAPID POINT-OF-CARE DIAGNOSTIC TEST INSTRUMENTS IN FIRST ROUND OF DISTRIBUTION
WHCA was notified this morning that 14 Washington skilled nursing facilities have been identified by CMS to receive the rapid PCC diagnostic testing equipment and supplies in the first round of distribution to states. The criteria for identification of these facilities by CMS is not known. According to CMS, the remaining facilities in the state and across the nation will be receiving their equipment and supplies over the next 14 weeks. As the first antigen Point-of-Care test devices are making their way to skilled nursing facilities in several states, AHCA has put together a brief document summarizing key information providers should be aware of before utilizing these test devices. Most notably, the CARES Act requires all laboratories with a CLIA certificate to report the results of every COVID-19 test that they conduct (positives and negatives) to the appropriate state or local public health department. This applies to nursing homes using these devices and is in addition to the reporting completed through the CDC NHSN website. 

There remains a multitude of unanswered questions related to the distribution and use of these devices in our skilled nursing facilities. While some of these questions are addressed in the CMS FAQ document, there remain a myriad of glaring questions on which we are awaiting guidance and further clarification, such as the costs associated with conducting these tests, who the tests are to be conducted on and when, how to report test results, who is qualified to conduct the tests, how to process and manage test results, the need for orders, billing, etc. As WHCA obtains more information regarding this issue, we will promptly make you aware. If you have additional questions and concerns, please reach out to Elena Madrid.
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.