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Virtual Spring Conference Live Session Schedule:
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May 7th, 10 - 11 AM: Evolving Trends: The New Generation of Therapy Services;
Presenter: Sarah Wendel of HealthPro Heritage
May 8th, 10 -11 AM: Employment Issues during COVID-19 Pandemic; Presenter: Doris Bronsan of von Briesen & Roper
Don’t worry, if you are unable to attend a live session, it will be recorded and added as an on-demand session, that you may view in accordance with your own schedule.
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COVID-19 Updates: May 6, 2020
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This update includes:
- DHS Releases Draft SNF COVID-19 Transfer Guidance Documents
- DHHS Clarifies Overpayment Questions
- NHSN COVID-19 Retrospective Reporting to January 1st Optional
- New Resource Documents for PPE Use and Conservation
- Bureau of Assisted Living Regulatory Response to COVID-19 – Assisted Living Forum Thursday, May 7, 2020
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As of today, there are 8,901 confirmed cases of COVID-19 in the state of Wisconsin and 362 deaths caused by the virus. Click
HERE
to view the latest outbreak information from the Wisconsin Department of Health Services. Click
HERE
to view COVID-19 projections for Wisconsin and the United States.
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DHS Releases Draft SNF COVID-19 Transfer Guidance Documents
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The Wisconsin Department of Health Services released two documents Tuesday evening that provide draft guidance on the transfer of nursing home residents between the hospital and SNFs.
The DHS Long-Term Care Subcommittee of the State Disaster Medical Advisory Committee (SDMAC) crafted the documents, which are designed to provide guidance to NHAs, DONs, and hospital discharge planners. While the papers do not constitute actual regulatory requirements, these guidance documents provide perspective on important clinical, operational, and epidemiological matters related to expectations for LTC facilities and hospitals. The documents should be reviewed by all members concerned about partnerships with acute care providers and health systems in the era of COVID-19.
The two documents advanced by the SDMC LTC sub-committee that were advanced for public comment are available on the
WI public meetings site and are linked directly here:
Public comments may be submitted to
DHSSDMAC@dhs.wisconsin.gov. The public comment period will close at
5 p.m. on Sunday, May 10, 2020.
John Vander Meer, President & CEO of WHCA/WiCAL served as an active member of the SDMAC-LTC sub-committee, which was charged with crafting the documents via video conference meetings in recent weeks. While several unsuccessful attempts by WHCA/WiCAL and other provider advocacy organizations to include the direct perspective of LTC providers on this committee, the composition of the committee was not expanded to include the direct perspective of LTC providers outside of the associations. WHCA/WiCAL will continue to advocate that any public committee affording acute care providers the opportunity to share their perspective should offer the same opportunity to LTC providers to have a direct voice on matters directly impacting the provider community in Wisconsin.
Vander Meer worked along with fellow committee members representing the LTC profession and consulted with WHCA/WiCAL member representatives to ensure the prospective of LTC providers was heard throughout the process and that documents fair to both sides were developed.
“I would like to thank my colleagues John Sauer, of LeadingAge Wisconsin; Dr. Ron Schreiber, of WAMD; and Joey Pettis, of the DON Council for working collaboratively to make sure that providers’ voices were heard in this process. I would also like to thank our fellow committee members from the acute care provider community who consistently heard our perspective on the concerns of our members, and were willing to seek reasonable compromise,” Vander Meer said. “I am also pleased to thank Brian Purtell and Jim Stoa for their keen legal and policy perspectives on these documents which demonstrably improved the language from the perspective SNF providers as a result of WHCA/WiCAL’s efforts. Pat Boyer’s clinical perspective and engagement with other stakeholders was also valuable throughout this process. This was all a team effort all around for Wisconsin’s LTC provider community.”
WHCA/WiCAL will be submitting comments on the documents and the process to DHS Secretary-Designee Andrea Palm. If any members would like to have their concerns voiced in WHCA/WiCAL’s letter to DHS, please send them to
John Vander Meer.
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NHSN COVID-19 Retrospective Reporting to January 1st Optional
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There has been some confusion as to whether retrospective reporting in
NHSN COVID-19 module is required or not. AHCA has confirmed with CDC that it is optional to submit data back to January 1, 2020. CDC also stated that retrospective reporting was optional at the end of its pre-recorded NHSN training webinar yesterday (Tuesday, May 5). CDC is working on revisions to the NHSN guide and instructions to make this clearer. We are also expecting CMS to issue a memo this week that will answer several questions that have been raised about this requirement as well as the new resident, representative, family notification requirement.
As a reminder, the new rule requires reporting starting last Friday, May 1, which must be done at least weekly. This makes Friday, May 8 the end of the first reporting period.
AHCA continues to advocate for CMS to allow a grace period from enforcement due to the
length of time necessary for nursing homes to gain access to NHSN as well as time needed to establish systems for reporting.
NHSN COVID-19 reporting is not required but
optional for assisted living communities. Assisted living communities should follow specific state reporting requirements and can consult
AHCA/NCAL’s guidance on notifications.
AHCA has been in touch with CMS directly on behalf of our ICF/IID providers and whether this is optional for them. On the NHSN site, there is a category for LTC/DD, but the CMS rule itself does not list ICF/IID as a provider type. We will keep our ID/DD providers updated once we have more information to share.
Also, CDC is offering several live Q&A sessions for nursing homes between May 6-14. Details can be found on the
CDC NHSN website. Scroll down to the training section.
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DHHS Clarifies Overpayment Questions
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In the past weeks, AHCA/NCAL has submitted an array of questions on the Provider Relief Fund as well as suggested Provider Relief Fund FAQ clarifications. Of particular importance, health care providers have expressed concern about interplay among the April 10 and 17 allocations with the second distribution that began on April 24. The primary concern has been that if a "gross receipts" methodology is applied across both tranches, providers might have to give back tranche 1 money even if they have sufficient COVID-related expenses or lost revenues which consume the April 10 funds based upon the Medicare FFS methodology.
Recently, the U.S Department of Health and Human Services (DHHS) staff has indicated they do not intend to recover Provider Relief Fund allocations unless:
- DHHS identifies an overpayment associated with revenue calculations which were incorrect based upon improper or incorrect information on the cost reports. DHHS also noted the Department is collecting tax filing information to be uploaded to verify the revenue. AHCA/NCAL recognizes the challenges associated with using tax filing information and is conveying those concerns to the Department; and
- DHHS will pursue providers who cannot substantiate the costs/loss of revenue. AHCA has developed a COVID Loss/Cost Calculator. To download a copy of AHCA/NCAL Grant and Loan Management Guide and of the calculator, click here.
Background on Awards
DHHS based the April 10 and 17 allocations on a provider's 2019 Medicare fee-for-service claims data. Providers received approximately 6.2% of that amount with an intended total of $30 billion across the whole Medicare program. Of the $30 billion, $29.6 were distributed on April 10 and $4 billion on April 17.
On April 24, DHHS released the second tranche based on 2% of the providers "net patient revenue" for 2018. Use of the term "net patient revenue" created confusion while the attestation web portal notes "Gross Receipts or Sales." It appears, DHHS' intent is gross receipts as a tax return term which indicates revenue after deductions such as contractual allowances which are customary in health care. An additional concern associated with the attestation language is the term "overpayment." DHHS has indicated that "overpayment " is meant to address situations where fund distribution calculation is in error. Specifically, this portion of the requested data is intended to provide DHHS with information to account for misalignment of a tranche 1 award with Medicare fee-for-service net revenues or tranche 2 payments based on 2018 cost report data.
DHHS will be issuing an FAQ to clarify the tranche 1 and 2 payment concerns and to address AHCA/NCAL questions such as Change in Ownership (CHOW) and problematic Tax Identification Number (TIN) scenarios (i.e., single TIN for multiple sources of revenue or businesses, no TIN if county owned, etc.). If they are unable to finalize the FAQ in time to have providers submit an attestation by the 30 day deadline, DHHS will extend the deadline.
AHCA/NCAL Member Support
AHCA will be developing an array of member support materials once DHHS releases the updated materials. These will include:
- Strategies to Address DHHS Recovery Scenarios Described in items 1 and 2, above;
- Updated AHCA/NCAL Grant and Loan Management Guide; and
- Provider Relief Fund Reporting Template.
Additionally, the Association will continue to pursue questions and concerns associated with using data such as tax filings. If you have questions or concerns, please contact WHCA/WiCAL Director of Reimbursement Policy
Kate Dickson.
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New Resource Documents for PPE Use and Conservation
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The Department of Health Services (DHS) has developed several new personal protective equipment (PPE) resource documents. These one-pagers provide recommendations on how to use and conserve PPE and are titled
In addition, a group called The Masked Sewist has a form for facilities in Milwaukee, Ozaukee, Washington, and Waukesha counties to fill out for homemade masks. Click
HERE for more information.
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Bureau of Assisted Living Regulatory Response to COVID-19 – Assisted Living Forum Thursday, May 7, 2020
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Assisted living providers and stakeholders are invited to attend twice a week Assisted Living Forums. During this time, Bureau of Assisted Living will provide answers to questions related to COVID-19 and assisted living facilities.
These sessions are conducted on Tuesday and Thursday from 10-11 a.m. until further notice. Please join on Thursday, May 7, 2020.
To Join:
Meeting ID: 723 961 504
Or by Phone: +1 312 626 6799
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Pat Boyer, MSM, RN, NHA
| Director of Quality Advancement and Education |
pat@whcawical.org
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