March 14, 2020

CMS Issues Revised Memo on Visitor Restrictions
On Friday, March 13, CMS issued CMS QSO-20-14-NH (revised) memo outlining new visitor restrictions and social distancing directives for nursing homes. In relation to this development, Skilled Nursing News published an article on the visitor ban, featuring Robin Dale. On Monday, March 16, the Department of Social and Health Services (DSHS) will issue a Dear Administrator letter with additional information via the NH Gov Delivery distribution list. Click here for a summary of the memo. Click here to sign up for the DSHS nursing home distribution service. 

The Trump administration emergency declaration for COVID-19 response is driving additional guidance from CMS:

• Click here for the March 13, 2020, CMS press release. 
• Of note, CMS will temporarily suspend non-emergency survey inspections, allowing providers to focus on the most current serious health and safety threats, like infectious disease and abuse. The Guidance will be issued this week, and we will brief you accordingly. 
Additionally, State Medicaid agencies will be provided flexibility and relief. The emergency declaration also enables CMS to grant state Medicaid agencies a wider range of flexibilities under Section 1135 waivers, including the ability to permit out-of-state providers to render services, allow providers to provide care in alternative settings, waive prior authorization requirements, and temporarily suspend certain pre-admission and annual screenings for nursing home residents. We will keep you apprised as DSHS begins to adopt changes to process.

The guidance does not apply to assisted living; however, the risk to residents is just as serious. 

Governor Jay Inslee has instituted a limited visitation policy in Washington that applies to assisted living communities, and the Centers for Disease Control and Prevention (CDC) guidance states much of the information in the CMS directive could also be applied in assisted living. It’s worth reviewing. 

School Districts Ramping Up to Support Childcare Needs
Summer break came early, and no one was truly prepared. Schools across the state will be closed through April 24, 2020. Families are faced with new challenges around childcare and daycare. Some families are also faced with additional hardship around food supply and meals delivered through school nutrition programs. School districts around the state are scrambling to provide resources. Some are working on plans that may include daycare or childcare options for school-aged children during the closure. Encourage your workers to check with their local school districts regarding resources.  

While we work to identify funding and resources from state and federal agencies related to childcare needs, we understand that there is a grassroots movement underway to address childcare needs. The Facebook community is abuzz with alternative childcare options, including care provided by family members, college students who have returned to the community, siblings, co-workers on opposite shifts than you, or friends. We applaud the community spirit—and will be vigilant in alerting you about resources for your working parents. 

Medicare Claims Processing for COVID-19
CMS Releases MAC-by-MAC Medicare Part B COVID-19 Test Billing Rates

The Medicare claims processing systems will be able to accept HCPCS codes (U0001, U0002) starting on April 1, 2020, for dates of service on or after February 4, 2020. It is important to note that Local Medicare Administrative Contractors (MACs) are responsible for developing the payment amount for claims they receive for these newly-created HCPCS codes in their respective jurisdictions until Medicare establishes national payment rates. View a map of CMS MAC coverage and the MAC-by-MAC rates. For details on how to submit billing, please check your MAC websites and/or call the provider support number. 

The relevant CMS guidance on Medicare Coverage and Payment Related to COVID-19 is located here

We anticipate additional guidance from CMS on these issues:

• Three-Day Stay Waiver: President Trump announced suspension of the Medicare’s three-day stay requirement before a skilled nursing facility admission. 
• MDS Completion and Submission Waivers: CMS is waiving 42 CFR 483.20 to provide relief to skilled nursing facilities on the timeframe requirements for Minimum Data Set (MDS) assessments and transmissions. 
• SNF Part A 100-Day Benefit Waiver: For “certain beneficiaries who recently exhausted their skilled nursing facility benefits, the waiver authorizes renewed skilled nursing facility coverage without first having to start a new benefit period.”
• Provider Location for Billing Waiver: “Temporarily waive requirements that out-of-state providers be licensed in the state where they are providing services when they are licensed in another state.” Note: this is for billing purposes and state licensing still needs to be followed. 

WHCA will continue to inform members regarding any impacts, regulatory changes, and resources available regarding COVID-19. Thank you for continuing to provide quality care and services to the residents and clients in your communities; you are remarkable.