COVID-19 UPDATE #128
January 19, 2021
UPDATED CDC GUIDANCE ON ANTIGEN TESTING IN LTC
The Centers for Disease Control and Prevention (CDC) recently updated its guidance on antigen testing in long term care facilities. Importantly, the CDC modified the algorithm on interpreting antigen tests to include:  
  • ​When to perform confirmatory PCR tests:  
  • ​Asymptomatic people who test antigen positive should have a confirmatory test performed.  
  • Symptomatic people who test antigen negative should have a confirmatory test performed.  
  • ​What to do with discordant results.  
  • Added new variables to the decision-making process (outbreak, close contact or no outbreak).  
  • Provided additional guidance on infection control measures to take in response to test results.  ​

Facilities should adhere to this new guidance when using antigen tests.
DOH AND L&I OFFER TRAINING ON N95 MASK FIT TESTING - TOMORROW!
The Department of Health (DOH) and Department of Labor and Industries (L&I) will be providing a webinar about Respiratory Protection Plans and N95 fit testing for long term care providers in Washington State. The webinar will take place tomorrow, January 20 at 11 AM. The first hour covers development of a respiratory protection plan and regulations related to use of N95 respirators. For those facilities who have a qualitative fit testing kit, the second hour will be a follow-along demonstration of qualitative fit testing procedures. This webinar is optional, and no educational credits will be provided. To register, please click here. Please note that the content from the January 13 webinar is the same. If you participated in that event, you do not need attend this event as it is the same information.
DEAR ADMINISTRATOR LETTER TO SNFs PROVIDES INSIGHT ON INTERIM RECOMMENDATIONS FOR CO-ADMINISTRATION OF COVID-19 VACCINE AND TB TESTING PRODUCTS
In a Dear Administrator letter to skilled nursing providers dated January 15, 2021, the Department conveys the Centers for Disease Control and Prevention (CDC) issued updated “Interim Clinical Considerations for Use of mRNA COVID-19 Vaccines Currently Authorized in the United States.” Under the section titled “Laboratory Reporting,” the CDC provided recommendations about the timing of the administration of the mRNA COVID-19 vaccine and Tuberculosis (TB) testing products.

The letter further shares that for either a Tuberculin Skin Test (TST) or an interferon gamma release assay (IGRA) test, the CDC recommends placing the tests prior to administering COVID-19 vaccine. If vaccine was already administered or a decision is made that receiving the vaccine is a greater priority than TB testing, the CDC recommends waiting until four weeks after the two-step vaccination process is completed before administering the TB test. The CDC also recommends
  • Performing TB symptom screening on all healthcare personnel or residents, and
  • All potential recipients of COVID-19 vaccination weigh the risks and benefits of delaying TST/IGRA with their providers. 

The letter explains that in situations where staff and resident/resident representatives prioritize the vaccine over TB testing, it places the nursing home in conflict with WAC 388-97-1380, which requires TB testing of staff and residents within 3 days of admission or employment. Residential Care Services (RCS) is writing emergency rules to modify WAC 388-97-1380 and WAC 388-97-1580 to permit deferral of TB testing in order for staff and residents to receive the COVID-19 vaccine. Facilities must complete TB testing as soon as permitted under the CDC guidance on the COVID-19 vaccine.
INTERIM RECOMMENDATIONS FOR CO-ADMINISTRATION OF COVID-19 VACCINE AND TB TESTING FOR ASSISTED LIVING
Recently the CDC provided recommendations about timing of the COVID-19 vaccine and tuberculosis (TB) testing products. The information is located here.

For either a TB skin test or an interferon gamma release assay (IGRA) test, the CDC recommends placing these tests in staff before administering the COVID-19 vaccine. If this is not possible, the CDC recommends waiting until four weeks after the two-step COVID-19 vaccine before administering the TB test. 

While the TB skin test requirement for all newly-hired staff is currently waived by emergency rule, many assisted living facilities have continued with the regulation as outlined in WAC 388-78A.  Should you need to miss the TB skin testing in order for a newly-hired employee to take the COVID-19 vaccine, ensure you perform a TB symptom screening and document the findings for the employee’s file.
COVID-19 BENEFIT PERIOD WAIVER CODING TIP
The Centers for Medicare and Medicaid Services (CMS) last year provided updated clarifications to SNF Medicare Part A billing guidance when applying COVID-19 coverage waivers in MLN Matters Article SE20011. Since then, some providers have received denials that have been identified as provider data entry errors.  

Specifically, when a SNF is requesting a benefit period waiver for beneficiaries that qualify for the one-time additional benefit period without a 60-day break in spell of illness, CMS instructs providers to do the following: 

  • ​For ALL SNF benefit period waiver claims, include the following (within the same spell of illness): 
  • ​Condition code DR - Identifies the claims as related to the PHE. 
  • Condition code 57 (readmission) - This will bypass edits related to the 3-day stay being within 30 days. 
  • COVID100 in the remarks - This identifies the claim as a benefit period waiver request.    
CMS has identified that data entry errors in the remarks field not following the above guidance may create processing problems.  

The American Health Care Association (AHCA) has provided this Coding TIP: When entering “COVID100” in the remarks, provider billers must not insert any spaces between “COVID” and “100” and must not add any additional information in the remarks field. Providers should forward this information to billing staff. 
COVID-19 MONOCLONAL ANTIBODIES UPDATE
The U.S. Department of Health and Human Services (HHS) Office of the Assistant Secretary for Preparedness and Response (ASPR) has announced that over 691,969 patient courses of COVID-19 monoclonal antibodies (mAb) have been allocated to over 4,097 sites across the country. This includes those engaged by the Special Projects for Equitable and Efficient Distribution (SPEED) to Priority Populations, which includes long term care (LTC) facilities.  

Project SPEED was developed to facilitate getting the mAb into non-hospital/non-hospital affiliated facilities that serve priority populations. Through SPEED, the American Society of Consultant Pharmacists (ASCP) and AMDA (the Society for Post-Acute and Long-Term Care Medicine) partnered to develop a readiness document for LTC facilities and pharmacies. If your center is interested in providing mAb to the residents it serves, you should check with your local pharmacy provider to see if they are able to provide this treatment.  

In addition, the National Home Infusion Association (NHIA) has provided a PDF listing of home infusion providers who are engaged in the pilot program to offer mAb to non-hospital facilities. Administration of mAb can best be facilitated through the utilization of large gathering rooms, such as a chapel or activity center, where multiple administration stations can be set up. Administration of the mAb is over the course of one-hour infusion, and there is an additional hour post-administration for monitoring and evaluation. A large room can accommodate multiple residents being infused at one time, which limits the number of staff who must be present to administer and observe the patients during and post-infusion.   

For more information on SPEED or to find out how to participate in the SPEED program, email ASPRStakeholder@hhs.gov.
CMS RESPONDS TO FOLLOW-UP QUESTIONS RELATED TO NEW COVID-19 ICD-10 CODES AND CODING
New ICD-10 codes were recently introduced off-cycle for COVID-19 effective January 1, 2021, and the Centers for Medicare and Medicaid Services (CMS) posted updated coding guidance when there was a COVID-related condition. Additionally, CMS also updated the PDPM Mappings file to incorporate the newly-introduced codes. Some of the new COVID-19 related codes map to RTP and cannot be used as primary reason for SNF stay in item I0020B of the MDS. 

The American Health Care Association (AHCA) also raised concerns about coding on a PPS 5-day or IPA assessment if the patient has previously tested positive for COVID and was symptomatic, but since then, has tested negative but needs skilled care due to a COVID-related condition (i.e., pneumonia). AHCA/NCAL asked CMS to clarify and did receive a response. Click here for the CMS response.
PROJECT ECHO COVID-19 ACTION NETWORK | ENGAGEMENT AND FEEDBACK
All long term care facilities are encouraged to participate in the 16-week National Nursing Home COVID-19 Action Network for Best Practices on Coronavirus Control virtual training and mentoring program. For those who have already participated, the project seeks feedback.

For those who are already registered, you can provide feedback on the Network by completing this short survey by Wednesday, January 27, at 11 PM EST. Centers that are not yet registered can find more information on this free program and register here, as there are new cohorts being formed through the end of January.
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.