Coronavirus Update #65
CMS Memo, Communication Strategies, AHCA Flowcharts, NSNCW,
CARES Act Info, Emergency Preparedness Reminders
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CMS Memo on Reporting Confirmed Cases
Late Sunday,
CMS announced
that it will be releasing new requirements for reporting and notification of confirmed COVID-19 among residents and staff.
CMS will be issuing these requirements through rulemaking in the coming days. These requirements will go into effect once the rule is issued. We don’t know at this time whether CMS will accept public comments upon issuance of the rule.
These new requirements will update previous notification guidelines shared by AHCA/NCAL for confirmed COVID-19 cases. We will share revised guidance and support materials once the regulations are released.
The announcement by CMS late Sunday applies only to nursing homes, so assisted living communities and facilities that serve the ID/DD population should continue to follow
AHCA/NCAL’s guidance
on notifications.
Notification of Confirmed or Suspected COVID-19
CMS and CDC will soon issue direction on standard formatting and frequency for all providers to report this information through the
CDC’s National Health Safety Network (NHSN) system
.
CMS states this information will be used to support local and national surveillance, monitor trends in infection rates, and inform public health policies and actions. The information may be publicly reported.
Current
CDC guidance
specifies that nursing homes notify State or Local health department about residents or staff with suspected or confirmed COVID-19, residents with severe respiratory infection resulting in hospitalization or death, or 3 or more residents or staff with new-onset respiratory symptoms within 72 hours of each other.
Notifying Residents and their Representatives
In addition, CMS will also issue through rulemaking new requirements to notify residents and their representatives to provide updates on new cases of COVID-19, new suspected cases, and facility actions and responses.
Specifically, nursing homes will be required to inform residents and their representatives
within 12 hours
of:
- The occurrence of a single confirmed infection of COVID-19, or
- The occurrence of three or more residents or staff with new onset of respiratory symptoms that occur within 72 hours.
Regardless of whether there are new confirmed infections or three or more residents or staff with new onset of symptoms in 72 hours, nursing homes will have to provide updates on the facility’s status to residents and their representatives at least weekly.
These notices must include information on mitigating actions implemented to prevent or reduce the risk of transmission, including any changes to facility operations.
The memo states this information must be reported in accordance with existing privacy regulations and statute, and we are requesting clarification on how this will be operationalized given these new notification requirements.
For compliance purposes, it is essential that providers keep records of notifications that have been made.
Additional Requirements
The memo states that failures to report confirmed or suspected cases or failure to provide required notifications to residents and representatives, could result in an enforcement action by CMS.
CMS reminds providers of the requirements to permit access to nursing home residents and representatives by any representative of the Secretary or the State, in accordance with regulatory requirements at §483.10(f) (4)(i)(A) and (B). CMS indicates CDC may conduct additional on-site infectious disease surveillance, testing of healthcare personnel and residents, or other related activities, as permitted under law. We will provide further information on this as soon as it is available.
These requirements will go into effect once rulemaking is issued.
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Communication Strategies for Keeping Families Up to Date
Effective communication is always important but is critical in this COVID-19 environment with heightened emotions, fear of the unknown, and restrictions on family member in-person visitation. Family members want to know that their loved one is safe, that providers are doing everything possible to protect their loved ones, and to feel a sense of connectedness especially because they can’t be with their loved ones.
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AHCA Skilled SNF Coverage Decisions Under COVID-19 Waivers Flowcharts
CMS recently updated their
SNF Medicare Part A coverage waiver guidance
. AHCA has developed visual flowchart guidance to help providers understand when longstanding CMS SNF Part A coverage policies apply, or when and how the Section 1135 waivers may be applied in various scenarios, including admissions and readmissions from hospitals, direct admissions from the community, and whether a SNF long-stay resident can be “skilled-in-place”.
Below are links to documents that contain flowcharts and step-by-step guidance to help providers identify whether a particular beneficiary is eligible for Part A benefits under: 1) normal coverage policies, 2) the COVID-19 3-day stay waiver, or 3) the COVID-19 spell-of-illness waiver, as well how a claim can be coded to indicate that a COVID-19 waiver applied to the beneficiary.
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National Skilled Nursing Care Week
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After much consideration, AHCA/NCAL has decided to recognize National Skilled Nursing Care Week (NSNCW) as scheduled
May 10-16, 2020.
Despite the challenges we face this year, it is more important than ever to recognize staff and residents in skilled nursing and post-acute care centers across the country.
We know that you and your staff are going to extraordinary lengths to keep residents safe from COVID-19. NSNCW presents an opportunity to acknowledge that and honor their hard work.
We encourage you to explore the following resources for ideas and suggestions on how you might celebrate despite the limitations of social distancing:
- Visit NSNCW.org for a revised list of activity ideas and links to the bookstore for special NSNCW products.
- Go to Facebook and Twitter using #NSNCW and #CareNotCOVID to share activity ideas, videos, and messages.
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CARES Act – Recipients Must Identify, Understand, and Comply with Grant and Contract Requirements
Numerous commentaries predict an outbreak of False Claims Act investigations and cases related to allegations of misuse, fraud, waste, and abuse of funding provided under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). Such predictions are surely accurate. With the tremendous sums of money at issue and the likely difficult economic conditions faced by many recipients, there are countless opportunities and temptations to misuse CARES Act funds.
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Use of the Incident Command System during infectious disease outbreaks
Compliance with
the Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers Final Rule indicates that skilled nursing facilities (SNF) along with other healthcare providers receiving Centers for Medicare & Medicaid Services funds implement an “All Hazards” approach to emergency preparedness. This rule requires healthcare facilities including skilled nursing facilities (SNF) to conduct a risk analysis of potential threats and perils through a process known as Hazard Vulnerability Assessment (HVA). One of the hazards typically identified in a comprehensive HVA is an infectious disease outbreak.
At first glance, long-term care providers may not always consider an infectious disease outbreak as a traditional emergency or disaster like a fire, flood, hurricane, earthquake or other adverse event. SNF operators should understand that that utilizing an “All Hazards” approach to manage each emergent situation is not only a requirement but will help promote a standardized and effective response.
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N-95 Mask Decontamination
Battelle’s Critical Care Decontamination Systems (CCDS), which is used to decontaminate N-95 masks, is now operational in Maryland.
The service is available at “no charge” to hospitals, first responders and other front-line workers for the next 6 months.
With a capacity of 80,000 N-95 masks a day, Battelle is trying to get the word out to hospitals in Baltimore and throughout Maryland about how they can sign-up and start having their masks decontaminated. Battelle is partnered with Cardinal Health to help with the logistics of picking up and dropping off the masks—also at no charge service to the user.
Here are a few useful documents about the decontamination science, the process to get mask cleaned, and the availability of this service at no cost.
Please contact Anne Ward at
[email protected] or
703.413.7244 with questions or for additional information.
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Webinar: Post-Acute Daily Bed Reporting via CRISP
As we shared yesterday, our partners at the Maryland Hospital Association (MHA) and CRISP have been working with post-acute providers and hospitals to streamline nursing home daily bed availability reporting.
There will be a webinar tomorrow, April 22 from 1:00 - 2:00 PM EST to go through the process of using this tool. Please see the call details below.
Post-Acute Daily Bed Reporting via CRISP
Date:
Wednesday, April 22
Time:
1:00 - 2:00 PM EST
Meeting number (access code)
: 316 561 900
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-OR-
Join by phone
Access code: 316 561 900
Who should attend: Post-acute and hospital personnel and others interested in post-acute daily bed availability.
What: The CRISP team will demonstrate detailed instructions on how to complete the daily bed reporting form and how to access summary reports. They will also cover anticipated changes to the reporting and distribution of information, and how to access summaries through CRISP’s public health reports. There will be time for Q & A.
More Background: The hope is that this reporting tool will be an easier and more comprehensive way to understand bed availability than current processes. The intent is to ask nursing home for key pieces of information that will not be overly burdensome and still provide enough information for hospitals to streamline post-acute care placement. Facilities will be allowed to enter data more than once per day if bed availability changes from first entry, but daily submissions will need to be completed by 10:00 am each morning.
All entries will be processed to provide a single source capacity directory that discharge planners and care managers can use to locate needed beds. Initially, this will be in the form of a spreadsheet emailed back to the discharge planners. Over time, it will also include display in CRISP.
Facilities that submit data will also be able to see daily bed availability across the state. You will need to be credentialed in CRISP to view data, but no credential is needed to submit.
Nursing homes can input information via this link:
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CMS COVID-19 Stakeholder Engagement Calls
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.
COVID-19 Office Hours Calls (Tuesdays and Thursdays at 5:00 – 6:00 PM Eastern)
Office Hour Calls provide an opportunity for hospitals, health systems, and providers to ask questions of agency officials regarding CMS’s temporary actions that empower local hospitals and healthcare systems to:Increase Hospital Capacity – CMS Hospitals Without Walls; Rapidly Expand the Healthcare Workforce; Put Patients Over Paperwork; and Further Promote Telehealth in Medicare.
Tuesday, April 21
5:00 – 6:00 PM EST
Toll Free Attendee Dial In: 833-614-0820
Access Passcode: 3963515
AND
Thursday, April 23
5:00 – 6:00 PM EST
Toll Free Attendee Dial In: 833-614-0820
Access Passcode: 5899488
Lessons from the Front Lines: COVID-19 (Fridays at 12:30 – 2:00 PM Eastern)
Lessons from the Front Lines calls are a joint effort between CMS Administrator Seema Verma, FDA Commissioner Stephen Hahn, MD, and the White House Coronavirus Task Force. Physicians and other clinicians are invited to share their experience, ideas, strategies, and insights with one another related to their COVID-19 response. There is an opportunity to ask questions of presenters.
Friday, April 24
12:30 – 2:00 PM EST
Toll Free Attendee Dial-In: 877-251-0301
Access Code: 5096006
Weekly COVID-19 Care Site-Specific Calls
CMS also hosts weekly calls for certain types of organizations to provide targeted updates on the agency’s latest COVID-19 guidance. One to two leaders in the field also share best practices with their peers. There is an opportunity to ask questions of presenters if time allows.
Home Health and Hospice (Tuesdays at 3:30 PM Eastern)
Tuesday, April 21
3:00 – 3:30 PM EST
Toll Free Attendee Dial-In: 833-614-0820
Access Passcode: 9895252
Nursing Homes Specific Calls (Wednesdays at 4:30 PM Eastern)
Wednesday, April 22
4:30 – 5:00 PM EST
Toll Free Attendee Dial-In: 833-614-0820
Access Passcode: 2672118
Dialysis Organizations (Wednesdays at 5:30 PM Eastern)
Wednesday, April 22
5:30 – 6:00 PM EST
Toll Free Attendee Dial-In: 833-614-0820
Access Passcode: 1796168
Nurse Specific Calls (Thursdays at 3:00 PM Eastern)
Thursday, April 23
3:00 – 3:30 PM EST
Toll Free Attendee Dial-In: 833-614-0820
Access Passcode: 6004019
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Who are your healthcare heroes?
During the COVID-19 pandemic, nursing home and assisted living healthcare workers are proving themselves not just essential workers, but frontline heroes. From managing a virus that can be spread without symptoms, to dealing with a shortage adequate testing and PPE, to being forced to rightfully isolate residents from families and loved ones, these challenges are immense, unprecedented, and heartbreaking. Nursing home and assisted living healthcare heroes are truly working hard and doing all they can to save lives.
As we previously shared, this week is national
Careers in Aging Week
. This week is happening in the most unusual of circumstances -- we are realizing more than ever before that for our best teams, this work is a calling. This week we will celebrate Maryland's 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.
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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.
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Additional Resources and Guidance
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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.
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