COVID-19 UPDATE #112 December 11, 2020

WHEN SHOULD PROVIDER RELIEF FUNDS BE ACCOUNTED FOR AS REVENUE?

There have been some confusion and differing opinions on revenue recognition for funds received under the CARES Act. Care providers have been provided with multiple tranches of funding under the CARES Act. They have also received funding through multiple outside sources of COVID-19-related funding including Medicaid, Federal Emergency Management Administration (FEMA), and insurance. The critical question is whether these should be entered on the provider’s ledger as revenue or as a liability as deferred revenue. The answer depends on whether the provider is reasonably certain the provider will meet all the requirements outlined in the Terms and Conditions associated with the various tranches of funding as well as associated reporting standards. Answers to these questions and more can be found here. Thanks to Bill Ulrich and the team at Consolidated Billing Services Inc. for providing this information.

DOH PROVIDES GUIDANCE ON COVID-19 VACCINATION ALLOCATION AND PRIORITIZATION IN PHASE 1A

The Washington State Department of Health has developed this guidance for COVID-19 vaccine allocation and prioritization to facilitate harmonized planning for distribution across Washington State. This guidance is the result of several months of engagement with expert groups and community partners to gather input and ideas. The guidance will be updated to provide details on the other phases based on: New information from clinical trials New federal guidance and vaccine recommendations Ongoing feedback from impacted communities, partners, sectors, and industries

UPDATED INFORMATION ON DOH POC TESTING REPORTING

In a Dear Provider letter dated December 2, 2020, assisted living and skilled nursing providers were informed that facilities administering point-of-care (POC) testing for COVID-19 (such as BD Veritor, Sofia Quidel, AbbottBinex NOW, and other similar COVID-19 antigen testing) must report all their COVID-19 testing results to the Department of Health (DOH). In recent meetings with the DOH, it was clarified that your facility is not required to report to the DOH if you are already reporting your POC testing data to your local health jurisdiction. DOH has updated the information on their website to include this direction. The process for reporting can be accessed via this link.   Please note, the first option on the list is the use of the National Healthcare Safety Network (NHSN). Many facilities have already started using this option. If your facility is already enrolled and has Level-3 access for reporting, continue to do so; however, at this time the DOH system is not able to accept results from the NHSN system. The DOH continues to work with NHSN to facilitate this data communication between the two systems. WHCA will update you when additional information is received.

DEAR PROVIDER LETTER INFORMS OF EMERGENCY RULES SUSPENDING TB TESTING

In a Dear Provider letter dated December 9, 2020, all providers are notified that the Department of Social and Health Services (DSHS) has filed CR-103E (WSR 20-24-060) emergency rules for tuberculosis (TB) testing requirements for long term care workers. The new emergency rules continue the suspension of requirements related to TB testing in WACs 388-76-10265, -10285, and -10290(1). These rules are suspended in response to the significant threat of COVID-19 to our most vulnerable populations, especially for those receiving long term care services in their homes and congregate settings, such as long term care facilities. Clinics providing TB testing continue to be short of staff and have limited availability throughout the state due to the COVID-19 outbreak. These clinics are unable to provide the TB testing required as a part of the hiring process in many long term care programs. These emergency rules are intended to help meet the demand for long term care workers in Washington State. Additionally, a CR-101 (WSR 20-16-069) was filed with the Office of the Code Reviser on July 29, 2020, to begin the rule-making process establishing a timeframe when long term care facility employees and residential service and support provider employees were not required to be screened for tuberculosis under the rules suspended or waived during the COVID-19 pandemic.

DEAR PROVIDER LETTER UPDATES SNFs ON COVID-19 TESTING SUPPLY

In a Dear Provider letter dated December 9, 2020, to all skilled nursing providers, Residential Care Services shares insight on COVID-19 testing supply. The letter explains that due to CMS testing requirements and the increased COVID-19 transmission rates placing heavy demand on antigen testing supplies, many facilities have reported difficulty getting supplies they need. The Washington State Department of Health (DOH) recently announced that facilities having difficulty obtaining enough testing supplies to meet testing requirements have an option to request testing supplies directly from DOH. The testing supplies are PCR (molecular) tests and DOH will bear the cost of the test supplies and the cost to send the test to a DOH contracted laboratory. If a facility sends the test samples to their own laboratory, DOH will not reimburse the facility for that lab cost. Availability of testing supplies is not guaranteed. The turnaround time for laboratory results is approximately 48 hours. DOH will assign a DOH-contracted laboratory for a facility to use. If the facility has not used the laboratory before, there will be instructions about how to work with the assigned laboratory and how to ship test samples. To request testing supplies from DOH, please use this Smart Sheets link to fill out a request form. If you have additional questions, please email DOH. If you have any questions, please email Lisa Herke, Nursing Home Program Policy Unit Manager, or call her at (509) 209-3088.

DEAR PROVIDER LETTER ANNOUNCES FILING OF CR-103 TO EXTEND NURSING HOME EMERGENCY RULES

In a Dear Provider letter dated December 9, 2020, to skilled nursing facility providers, Residential Care Services (RCS) conveys they have filed a CR-103E (WSR 21-01-035) to extend the emergency rules for some nursing home requirements a second time. The extension was effective December 9, 2020, and the rules expire on April 6, 2021. The following rules are amended, suspended, or temporarily repealed: Transfer and discharge rules: Amendment of WAC 388-97-0120 suspends the requirement to provide a bed-hold notice to a resident who leaves the facility. Resident assessment: Amendment of WAC 388-97-1000 removes the timeline requirements from the required resident assessment. Care planning: Amendment of WAC 388-97-1020 removes the requirement to develop a care plan within seven days of completion of the resident assessment. PASRR: WACs 388-97-1915 and 388-97-1975 were amended to permit the level I screening, and if needed, the level II evaluation to occur up to 30 days after admission. Resident groups: WAC 388-97-0920 ensures residents can participate in resident and family groups. The WAC was temporarily repealed. If you have any questions, please email Lisa Herke, Nursing Home Policy Program Manager, or call her at (509) 209-3088.

OSHA ISSUES NEW GUIDANCE ON REPORTING OBLIGATIONS FOR COVID-19, PPE SHORTAGES, AND N95 OPTIMIZATION

On September 30, 2020, the Department of Labor’s Occupational Safety and Health Administration (OSHA) released new guidance regarding an employer’s obligation to report and record work-related COVID-19 cases. In its guidance, OSHA defines the term “incident” that triggers the time period for calculating whether a case meets the reportability criteria. Read more here.   In addition, they’ve released specific information regarding options for optimization of disposable N95 respirators in healthcare settings, helping facilities decide what to do when supplies run short or are unavailable. Facilities are advised to follow these steps when PPE supplies run low:  Assess the work environment to determine specifically which job activities involve exposure to COVID-19, particularly highest risk exposure, which CDC defines as direct care for those with active respiratory treatments (e.g. nebulizer, suctioning,  trach or ventilator care). Based upon that assessment, determine specifically what type of PPE is necessary to protect employees performing those job activities from COVID-19 using CDC conservation methods. Make a good faith effort to acquire that PPE from commercial vendors or other employers in the community and contacting the local or state health department. Document all efforts to obtain the PPE and continue to periodically attempt to replenish the supply. Document those additional efforts. If PPE is unavailable, determine if additional engineering, administrative, or work practice controls can be implemented to eliminate or reduce exposures to COVID-19 including: Isolating areas of the facility for COVID-19 residents; Performing additional cleaning and disinfecting of the facility; Increasing the frequency of hand sanitizing; and Excluding healthcare personnel at higher risk of severe illness from COVID-19 from contact with known or suspected COVID-19 residents.   Read the entire PPE optimization guidance here. Special thanks to AHCA/NCAL for providing this information.

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.