Coronavirus Update #86
New Guidance on Federal Reporting, Reminder on State Reporting, MDH Order,
Medline PPE Survey, Healthcare Heroes, Testing Resources, Upcoming CMS Calls
New Guidance Available on Requirements for Notification of Confirmed and Suspected COVID-19 Cases Among Residents and Staff in Nursing Homes

CMS issued a memo and frequently asked questions addressing the new requirement that nursing homes and long term care facilities report COVID-19 facility data to the Centers for Disease Control and Prevention (CDC) and to residents, their representatives, and their families. This action, included in the recent Interim Final Rule with Comment Period, will support surveillance of COVID-19 cases and increase transparency. See the QSO memo here.

Howard Sollins , leader of Baker Donelson's Long Term Care Team is H FAM's attorney of record and trusted authority on regulatory issues. We encourage providers to reach out to him with any questions at [email protected].

Some highlights from the memo are listed below. There are some important implementation dates providers need to know.  These requirements go into effect with the publication in the Federal Register of the interim final rule   on May 8, 2020. 

CMS had previously communicated the effective date was May 1. However, CMS revised the effective date to be May 8, 2020.  

  • The effective date means nursing homes are required to begin notifications of residents, their representatives and families as of May 8. This means the first notification could be required to occur by May 9 at 5 pm, should the facility have any of the resident and/or staff cases on May 8 as described by CMS required to make notification. 

  • Action: Ensure system and processes for notifications are in place in your facility by May 8 to meet new requirements.  

Facilities must submit their first set of data by 11:59 pm on Sunday, May 17, 2020 to the NHSN Long-Term Care Facility COVID-19 Module.

  • Action: Register now for NHSN and begin collecting data starting May 8, 2020. [NOTE: registration is taking more time than expected and we encourage you to start now to avoid further delays that may impact your compliance.] 

  • The memo provides an overview of the registration process.  

  • For NHSN questions, please email: [email protected] and add “LTCF” in the subject header. 

CMS will provide facilities with an initial two-week grace period to begin reporting cases in the NHSN system (which ends at 11:59 p.m. on May 24, 2020) . Facilities that do not begin reporting after the third week (by 11:59 pm on May 31, 2020) will receive a warning letter reminding them to begin reporting the required information to the CDC. 

For facilities that have not started reporting in the NHSN system by 11:59 p.m. on June 7, ending the fourth week of reporting, CMS will impose a per day (PD) CMP of $1,000 for the failure to report that week. 

For each subsequent week that the facility fails to submit the required report, the noncompliance will result in an additional one-day PD CMP imposed at an amount increased by $500. For enforcement-related questions, please email: [email protected] . 

New COVID-19 F-tags & Updated Survey Tools 

CMS has established two new F-Tags - F884: COVID-19 Reporting to CDC and F885 COVID-19 Reporting to Residents, their Representatives, and Families. 

CMS has updated survey tools including COVID-19 Focused Survey for Nursing Homes, Entrance Conference Worksheet, COVID-19 Focused Survey Protocol, and Summary of the COVID-19 Focused Survey for Nursing Homes. These updated forms are posted to the Survey Resources folder in the COVID-19 Focused Survey sub-folder on the CMS Nursing Homes website. 

  • Action: Facilities should begin using the revised “COVID-19 Focused Survey for Nursing Homes” to perform their self-assessment. Surveyors will begin using these revised documents immediately.  

Public Posting of NHSN Data Anticipated By End of May 

CMS anticipates publicly posting CDC’s NHSN data (including facility names, number of COVID-19 suspected and confirmed cases, deaths, and other data as determined appropriate) weekly on Monday’s at https://data.cms.gov/  by the end of May. 

Multiple Q&A 

CMS provides 22 Q&A in the last 7 pages of the memo. Question 10 addresses retrospective reporting and reads as below: 

  • Q: Are facilities required to report data that predates the effective date (May 8) of the interim final rule? 

  • A: No, there is no requirement in the rule to collect older data.  
Reminder: State Reporting Requirements

As you know, the Maryland Department of Health (MDH) recently issued this nursing home reporting notice.

All Maryland nursing homes are required to submit daily reporting information through CRISP as required by COMAR 10.07.02.09L and Governor and Health Secretary orders and directives, issued during a declared State emergency and healthcare pandemic. Under Maryland Health General Article Sections 19-359 and 19-1401 et. seq., and COMAR 10.07.02.70 through .74, the Maryland Department of Health has the authority to impose a  civil money penalty   (CMP) based upon the existence of a deficiency at a nursing home.    The failure to comply with this directive constitutes a deficient practice.  

OHCQ will be monitoring compliance with this requirement on a daily basis and will issue daily CMPs for not reporting. Please ensure immediate and continued compliance.

Please note that the link in the MDH order does not link to the actual CRISP portal.    Form responses are only accepted between 12AM and 11AM eastern time.

This is the link to the reporting portal:


Should you have any questions, please contact: William (Bill) Hokemeyer, Jr. at 410.596.8205 or at [email protected]
Note on reporting: In Maryland, HFAM and our partners at LeadingAge, LifeSpan, CRISP, and MHA are working to coordinate efforts. Expect a future webinar on reporting requirements. In the meantime, please review and adhere to the federal guidelines in addition to the required daily state reporting through CRISP.
Reminder: Updated MDH Directive and Order

Yesterday the Maryland Department of Health released an AMENDED DIRECTIVE AND ORDER REGARDING VARIOUS HEALTHCARE MATTERS.

Please note that this Directive and Order replaces and supersedes the Directives and Orders Regarding Various Healthcare Matters, dated April 5, and March 23, 2020 and the Directive and Order regarding Availability of Testing dated March 20, 2020.
Medline PPE Survey

Given the unprecedented demand due to COVID-19, Medline is working on forecasting future production and inventory. With so much change, please help Medline understand what you believe you need for the remainder of this year and 2021. Please take this survey. The more insight that Medline can gather the better.
Healthcare Heroes
David Insel at FutureCare Cherrywood. Thank you!
Who are your healthcare heroes?

There are so many amazing stories of dedication, sacrifice, and compassion by long term care professionals who are going above and beyond to ensure the safety, health, and happiness of residents during this unprecedented time. These individuals are saving lives; they are heroes.

We want to hear your stories! Please email      [email protected]     to share a current story and picture of members of your team who are going above beyond to provide quality care during this unprecedented time. 
Testing Resources

First Call Medical Center,  an urgent care clinic located in Gambrills, is available to provide testing to staff and residents of long-term care centers. Skilled nursing centers and assisted living campuses may set up testing for staff and/or residents in several ways: staff can utilize the urgent care’s drive through testing, the urgent care clinic can set up at your center, or a mix of these options. Please note for staff testing, it is most efficient to send employee information ahead of the testing in order for the clinic to process tests quicker. This testing is available 7 days a week.

In addition, this urgent care clinic has adequate access to PPE and they are even offering to share PPE (including face shields and masks) with other providers.

Please contact Dr. Ron Elfenbein to discuss the testing process and figure out which option works best for your center. Dr. Elfenbein can be reached via email at     [email protected]   or via phone at 410-507-9698 (please leave a message if no answer).


Diamond Medical Labs,  located in Owings Mills, has the capacity to do in-residence test collection for seniors during the COVID-19 outbreak so that they do not have to go out. Contact Andy Diamond at     [email protected]  or   443-992-2782  if there is demand at your center or if you would like additional information.


The Maryland Department of Health Laboratory  -    click here  for more information.


MAXIMUS

As testing capacity and supplies grow to meet demand, logistical issues around coordination, wait times and locations will become salient challenges to nursing homes. Criteria and referrals for getting tested have been unclear and will evolve as more and more tests come online.  Simplifying the testing process for nursing home residents is vital to keeping confidence high.

MAXIMUS can assist nursing homes with support for referred patients:

  • Manpower – It can provide qualified, background-checked service representatives quickly.
  • Test Screening – It can provide called screening services to identify symptomatic people who need priority testing.
 
MAXIMUS brings relevant experience

  • State of New York COVID-19 Screening and Scheduling – Since mid-April, MAXIMUS has screened and scheduled testing for more than 10,000 New Yorkers through our NYS COVID-19 Hotline.
  • Department of Veterans Affairs (VA) Choice and Mission Programs – MAXIMUS providea medical appointment scheduling services for 1.5 million veterans and 440,000 providers.
  • National HHS COVID-19 Test Result Notification Center – In just six days, MAXIMUS was able to stand up a multichannel call center for the U.S. Department of Health and Human Services (HHS). Operations now support 10,000 individuals per day with COVID-19 test results – providing geo-mapping of real-time test results to HHS staff.
 
MAXIMUS has the capability and capacity to help

MAXIMUS is the largest provider of turnkey contact center services to government programs, including 1-800-MEDICARE and 1-800-CDC-INFO (which we expanded to 24/7 service in response to COVID-19).

  • Unmatched capacity – More than 20,000 service agents working in over 60 MAXIMUS locations across 30 states, handling over 5.7 million calls each month – with nearly 70% of U.S. workforce working from home.
  • Ability to provide manpower, equipment and cloud-based services – MAXIMUS’s AWS-based, HIPAA-compliant solution offers secure access to your systems and the communications channels citizens prefer – especially personal mobile devices.
  • Decades of experience working with the populations at the front lines of your COVID-19 response – MAXIMUS supports state-based programs, including 100 state-based contact centers and 17 eligibility related program operations

If you are interested in setting up a coronavirus testing program, please contact Leonard Lucchi  [email protected]  or 410-280-2203.
CMS COVID-19 Stakeholder Engagement Calls – Week of 5/04/20

CMS hosts varied recurring stakeholder engagement sessions to share information related to the agency’s response to COVID-19. These sessions are open to members of the healthcare community and are intended to provide updates, share best practices among peers, and offer attendees an opportunity to ask questions of CMS and other subject matter experts.


  • CMS COVID-19 Office Hours Calls (Tuesdays and Thursdays at 5:00 – 6:00 PM Eastern

  • Lessons from the Front Lines: COVID-19 (Fridays at 12:30 – 2:00 PM Eastern)

  • Weekly COVID-19 Care Site-Specific Calls:

  • Home Health and Hospice (Tuesdays at 3:00 PM Eastern)
  • Nursing Homes (Wednesdays at 4:30 PM Eastern)
  • Dialysis Organizations (Wednesdays at 5:30 PM Eastern)
  • Nurses (Thursdays at 3:00 PM Eastern)
Did you miss HFAM's previous alerts?

Visit our website to view all previous HFAM alerts, as well as guidance
from our federal and state partners.
Thank you.

We cannot thank you enough for the dedication and diligence in doing all that you can for the residents in your communities. HFAM continues to monitor the COVID-19 pandemic with our state and national partners and will do all we can to support you during this time.