Wednesday, May 27, 2020

Updated NCAL Guidance on Reporting in Assisted Living Communities


NCAL has updated guidance on notifications and reporting confirmed cases of COVID-19 in assisted living communities. NCAL encourages all assisted living communities to follow state and local requirements for reporting. Providers should use documented reporting information when reaching out to local county and state health departments when requesting assistance for supplies, such as personal protective equipment.

Senate Hearing on Caring for Seniors Amid the COVID-19 Crisis

Dana Ritchie

On Thursday, May 21, U.S. Senate Special Committee on Aging Committee held a hearing entitled, “Caring for Seniors Amid the COVID-19 Crisis.” The hearing featured three non-governmental witnesses that discussed how COVID-19 is affecting seniors, especially seniors receiving care in skilled nursing facilities, as well as other topics including personal protective equipment, infection control, data collection, regular testing of residents and staff, pandemic health care provider funding, and vaccines and treatments.

AHCA/NCAL submitted a statement for the record. You can watch a video recording of the hearing, and read the majority and minority press statements of the U.S. Senate Aging Chairman and Ranking Member.

NHSN Update and FAQs

Nursing facilities were required to submit their first set of data to NHSN by 11:59 pm on May 17, 2020 to be compliant with the new requirements. Facilities may choose to report more frequently, but at minimum must report at least once every seven days. The initial two-week grace period ends at 11:59 pm on May 24, 2020. Facilities that fail to begin reporting after the third week, ending at 11:59 pm on May 31, will receive a warning letter reminding them to begin reporting the required information to CDC/NHSN. Facilities who have not started reporting in the NHSN system by 11:59 pm on June 7th, ending the fourth week of reporting, CMS will impose a per day (PD) CMP of $1,000 for one day for the failure to report that week. Each subsequent week that the facility fails to report will result in an additional one day PD CMP imposed at an amount increased by $500.

NHSN updated the instructions for the pathway forms on May 12. When completing the data collection and upload, be sure that you are using the most current instructions. You can find the new instructions on the NHSN website. During one of the NHSN data reporting webinars, the NHSN team identified that each item question must have an answer entered or it will be counted as missing data and it will be counted as not being reported. When you enter count data, even if the answer is nothing or zero, you must enter 0 in the data field. If you leave it empty, it will be flagged as “no answer”.

According to the CDC, “to maintain consistency in reporting, if a facility is using crisis level strategies” the facility is experiencing a shortage. “In other words, PPE strategies that do not commensurate with U.S. standards of care are considered as a shortage. For information in relation to CDC’s optimization strategies for PPE (standard, conventional, and crisis), we encourage facilities to refer to Optimize PPE Supply website.

A center can easily identify if they are missing data in the NSHN module by reviewing the calendar view page. Any pathway that is incomplete will be highlighted as a tan color. Pathways highlighted as green indicated all questions were answered. Missing pathway means the pathway has not been started. As of right now, NHSN does not send notices for incomplete data. Centers are encouraged to review the calendar view to ensure all four pathways are highlighted in green to ensure compliance with reporting to NHSN.

Centers are continuing to report a delay in being able to register and upload data to NHSN. There are also centers who are reporting significant delays in having their questions answered via NHSN help desk. Centers who are experiencing delays are encouraged to keep documentation of all attempts of
contacting NHSN and any communications you have with them.

Some centers are reporting that they are not receiving the Agreement to Participate and Consent email. If this is happening to your center and you do not receive the Agreement to Participate and Consent in your inbox for whatever reason, you should follow these instructions:
  1. Log-in to SAMS.
  2. Select Long-term Care Facility Component and your facility/group name.
  3. Click “Submit” to review the “Agreement to Participate and Consent”.
  4. Click ‘Accept’ next to the appropriate contact name.
  5. Click “Submit”. A pop-up notification will appear confirming this action.
  6. Click “ok” to acknowledge the notification.
If you log in to SAMS and see the “Annual Survey” alert on your facility homepage, you should follow these steps to remove the alert:
  1. On the facility homepage, click "Survey Required 2020" alert on the facility homepage to be directed to the online survey 
  2. Complete the "Facility Characteristics" section and scroll to the bottom to click "save" to submit your survey.


CARES Attestation Window Extended, Updated Guidance & Financial Resources

On Friday May 22, U.S. Department of Health and Human Services (HHS) extended the CARES Act Provider Relief Fund attestation window. This allows time to address additional questions and to offer providers time to collect necessary payment portal information. In the press statement, HHS announces that the attestation window and related acceptance of Terms and Conditions has been extended from 45 to 90 days from the date a provider received a payment to attest to and accept the Terms and Conditions or return the funds. Providers should have received emailed letters from HHS on Friday. Providers should have received emailed letters from HHS on Friday.

Members will need to identify the dates of each relief payment and identify their new attestation and Terms and Conditions acceptance date based on the extension. HHS updated the Fund FAQs twice this past week.

AHCA/NCAL has updated the COVID-Related Cost and Loss Calculator and prepared a guidance document on the CARES Act Provider Relief Fund (member login required for both resources). The guidance includes:

  • Updated AHCA/NCAL CARES Act Provider Relief Fund FAQs;
  • A merged version of Tranches 1 and 2 Terms and Conditions with easily identifiable changes as well as a redline version of the SNF Allocation Terms and Conditions showing differences relative to the Tranches 1 & 2 Terms and Conditions. SNF Allocation has its own Terms & Conditions. Each of the three versions of the T&C must be attested to using TINs and award dollar amounts; and
  • A table containing key FAQs and AHCA/NCAL interpretations of HHS guidance.

Questions about Award Amounts

If you have questions or concerns about Tranches 1, 2, 3 awards, contact the HHS Hotline at (866) 569-3522. HHS reported on Friday that the call center now has access to additional data and new HHS guidance to better answer questions. When calling have the following information ready:
  • TIN(s)
  • CCN(s)
  • Dollar Amount in question by tranche and by building
Also, if questions about Tranche 3, the SNF Allocation, also have the number of SNF certified beds (Medicare, Medicaid or both) as well as the amount you received and the amount you believe you should have received.

For Tranches 1 and 2, in its May 14 FAQ update, HHS provided an explanation of why a building might not have received a Tranche 2 allocation. The FAQ provides a formula and explanation of how a Tranche 1 award may have impacted eligibility for Tranche 2. See FAQs on page 7 of the updated FAQ document. HHS added Change in Ownership (CHOW) FAQs as well as TIN FAQs. The latter FAQs are called out in the AHCA/NCAL Guidance document in addition to inclusion in the HHS FAQs.

Next Steps – Additional CHOW, TIN, and Other Questions

AHCA/NCAL will continue to submit questions and examples of challenging fund scenarios to HHS including CHOW, TIN aggregation, disaggregation, and additional questions about financial terminology and use of tax filing data for validation. However, HHS has verbally indicated the Department’s goal is “maximum flexibility.” While we will continue work with them during the additional assentation window time, it is possible they will defer to reconciliation and reporting documentation to address all scenarios.

Revised OSHA Policies

The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) has adopted revised policies for enforcing OSHA’s COVID-19 requirements, which will become effective May 26, 2020. The previous memorandum will be rescinded.

OSHA is increasing in-person inspections at all types of workplaces. In geographic areas with sustained elevated community transmission or a resurgence, OSHA will prioritize on-site inspections for high-risk workplaces, such as health care providers treating patients with COVID-19.

OSHA is also revising its previous enforcement policy for recording cases of COVID-19. Under OSHA’s record keeping requirements, COVID-19 is a recordable illness. Employers are responsible for recording cases of COVID-19 if the case:
Under the new policy issued, OSHA will enforce recordkeeping requirements for employee COVID 19 illnesses for all employers. OSHA acknowledges the difficulty in determining whether a COVID 19 illness is work-related, especially when an employee has experienced potential exposure both in and out of the workplace. OSHA’s guidance emphasizes that employers must make reasonable efforts, based on the evidence available to the employer, to determine whether it would be considered work-related.

HHS Releases $4.9 Billion to Skilled Nursing Centers

On Friday, May 22 the federal government announced it will allocate $4.9 billion to certified skilled nursing centers, from the Provider Relief Fund created by the CARES Act.

Every provider, whether they have cases of COVID-19 or not, is fighting to protect residents or keep the virus out the building. This has required substantial outlays for PPE, testing, agency staff and hero pay for regular staff as providers isolate and cohort residents, prevent staff from working across units, and increase cleaning and infection control procedures. If a nursing home has COVID-19 positive patients, those costs double and triple.

Which is why AHCA/NCAL welcomed the news on funding in a press statement.

Providers will be paid electronically where possible. Providers who normally receive a paper check for reimbursement from CMS will receive a paper check in the mail for this payment as well, within the next few weeks.
  • HHS will make relief fund distributions to SNFs based on both a fixed basis and variable basis. 
  • Each SNF will receive a fixed distribution of $50,000, plus a distribution of $2,500 per bed. 
  • Providers must attest that they will only use Provider Relief Fund payments for permissible purposes and agree to comply with future government audit and reporting requirements. 
These resources are welcome news, but AHCA/NCAL is not done yet. We realize that many of you have mounting challenges in the weeks and months to come. AHCA/NCAL remains focused and committed to working on your behalf.

Tuesday, May 26, 2020

Dr. Nimale Stone from the CDC to Present at Telligen's LTC Office Hours

Holly Harmon

COVID-19 in LTC Office Hours: COVID-19 Testing Considerations & Cohorting
Thursday, May 28, 2020
1pm MT | 2pm CT | 3pm ET

Dr. Stone is the Team Lead for Long-term Care for the Prevention and Response Branch within CDC’s Division of Healthcare Quality Promotion. She is a board-certified infectious disease physician with over 10 years of experience developing surveillance and quality improvement projects to track and prevent infections and antibiotic resistant pathogens in post-acute and long-term care settings. In her role at CDC, Dr. Stone oversees the development of guidance, educational resources, and implementation tools to support infection prevention and antibiotic stewardship activities in nursing homes. Currently, she supports the teams developing and implementing CDC guidance and educational resources to support nursing homes and assisted living facilities preparing for and responding to COVID-19.

Please join: click here to register!

FedEx is Giving $1 Million to Small Businesses

Dave Kyllo

FedEx is committing to provide $1 million in grants for small businesses (fewer than 50 employees and less than $5 million in 2019 revenue) in the U.S. Each grant recipient will receive $5,000, plus a $500 credit from FedEx Office. AHCA/NCAL members can apply through June 12th at fedex.com/supportsmallgrants. But first, make sure you’re signed up for FedEx discounts through the AHCA/NCAL Shipping Program. If you’re not already taking advantage of this free benefit, enroll today.

Through the AHCA/NCAL Shipping Program, managed by PartnerShip, members receive exclusive discounts with FedEx, including up to 29% off select FedEx Express services. There are no fees or minimum shipping requirements, simply great savings and great efficiency. To participate in the AHCA/NCAL Shipping Program and receive discounts of up to 29%, simply enroll now or email sales@PartnerShip.com to start saving today. Enrollment is free.

Reach the Class of 2020 through the LTC Career Center

Dave Kyllo 

Open positions can be posted on the AHCA/NCAL Long Term Care Career Center for $350 per 30-day posting and is a great way to reach Spring graduates. 

The LTC Career Center gives unprecedented targeted national exposure because it connects with the Health Care Career Network by providing visibility on the network’s nearly 300 national and state health care organizations and societies. Serious health care candidates and new grads look for jobs on this national network built for health care employers to reach health care professionals. 

A 30-day posting gives even more value because employers who utilize the AHCA/NCAL Long Term Care Career Center receive free bonus exposure through rotating job listings on AHCA’s home page – the web site where long term care professionals go for news and information. In addition, employers that post vacancies through the AHCA/NCAL LTC Career Center get extra value through free rotating listings on the Long Term Care Career Center home page. 

Of course, the LTC Career Center is always free for job seekers and the LTC Career Center features many of the best positions the long term care profession has to offer. Graduates and experienced health care professionals utilize the Health Care Career Network to find the best health care openings. 

Visit the LTC Career Center Employer Page or call Robin at 866-964-2765 x2736 for more information about posting job vacancies on the LTC Career Center and other discounted job listing packages.   


Check Out AHCA/NCAL’s New Online Training for Improving Functional Outcomes

Dave Kyllo 

AHCA/NCAL has released a new online training titled Functional Outcomes Improvement and designed for all staff who have a role in improving patient functional outcomes quality and services, including nurses, CNAs, therapists, activities staff and recreational therapists. 

This course advances knowledge and skills about functional improvement through an array of learning tools and resources designed to meet the educational needs of various staff and departments. This includes learning about daily care best practices and real-world tools that improve functional outcomes. 

The Medicare Payment Advisory Commission (MedPAC), the IMPACT Act, and CMS called for the development of functional improvement measures based on the self-care and mobility sections of the Continuity Assessment Record and Evaluation (CARE) tool. 

The program is flexible and can be completed in one sitting or one module at a time. The training is delivered in five modules, including:

  • Module 1 – Explores the connection between functional outcomes and person-centered care, and how utilization of evidence-based pragmatic programs leads toward continuous improvement.
  • Module 2 – Reviews the regulations related to functional outcomes including the CMS Requirements of Participation and how functional improvement impacts reimbursement.
  • Module 3 – Covers best care coordination practices for short- and long-stay patients, including coordinating with therapy processes, and provides an overview of effective restorative nursing programs.
  • Module 4 – Closely examines care practice application and what individuals can do to increase function, team engagement and concludes with a discussion of various quality initiatives that lead to better outcomes.
  • Module 5 – Reviews the tools and resources needed to further functional outcomes improvement approaches to person-centered care.     

The cost for the training program is $199 for AHCA/NCAL members and $650 for non-members and offers 6.5 NAB CE credits for administrators and 6.5 contact hours for nurses through the Iowa Board of Nursing. There is a quiz at the end of four of the five modules and participants must pass a final exam with a score of 80 or higher to receive credit. Click here to register or go to ahcancal.org/functionaloutcomes

Members will need to login with their AHCA/NCAL usernames and passwords to register. For assistance obtaining AHCA/NCAL usernames and passwords, members should e-mail educate@ahca.org with their name and facility contact information. 


Wednesday, May 20, 2020

Reimbursement and Legal Issues Related to COVID-19 Testing in Long Term Care

Reimbursement Issues 

Medicare Coverage of Testing: Medicare fee for service and Medicare Advantage plans will cover the cost of COVID-19 diagnostic (PCR) tests. Tests range in cost from $115 to $500.  Medicare Part B will only reimburse approximate $100 for the PCR and $35 for other tests. However, not all labs will bill Medicare directly. AHCA/NCAL strongly recommends that, wherever possible, providers use labs that will bill Medicare, as providers may not be able to bill for these services.

CARES Act Coverage: The CARES Act requires health plans to cover the cost of COVID-19 testing for beneficiaries at no cost to the beneficiary. CMS is requiring Medicare Advantage Plans to cover the costs of testing for MA plan beneficiaries. Typically, however, when a test is required by an employer for employment, then the employer is responsible for the cost of the test. If the state is mandating testing the employer may not be held accountable for the cost of the test but this has not yet been validated.

CARES Act Grant Funds: The CARES Act Grant Funds can be used to cover costs for resident tests that are not otherwise reimbursable. This does NOT include testing for residents under a Part A stay where it is included in consolidated billing. 

Legal Issues 

Resident Refusals: Residents that refuse to be tested for COVID-19 cannot be discharged involuntarily, unless the facility is otherwise incapable of caring for residents with a confirmed diagnosis of COVID-19. 

Employee Refusals: Employers can make COVID-19 testing a condition of employment and terminate or not hire a person who refuses to obtain a COVID-19 test. 
 
For more information, please review the reimbursement and legal section of AHCA/NCAL’s Preparing for Widespread Testing in LTC Guidance

CMS Releases Additional Blanket Waivers

On May 11th, CMS issued additional waivers for the healthcare community that provide the flexibilities needed to take care of patients during the COVID-19 public health emergency (PHE). This is in addition to the waivers that were released on April 30. The following blanket waivers are in effect, with a retroactive effective date of March 1, 2020 through the end of the emergency declaration.

Paid Feeding Assistants 

CMS is modifying the minimum timeframe requirements for feeding assistant training to allow the training to be a minimum of 1 hour in length. CMS is not waiving any other requirements related to paid feeding assistants or the required training content which contains infection control training and other elements. Additionally, CMS is also not waiving or modifying the requirements which requires that a feeding assistant must work under the supervision of a registered nurse (RN) or licensed practical nurse (LPN).

With this waiver, AHCA/NCAL’s Temporary Feeding Assistant training is allowable. However, additional state requirements may need to be waived to permit individuals completing this program to assist with care in your location. We encourage you to contact your state survey agencies and state occupational licensing agencies, where applicable.

Specific Life Safety Code (LSC) for Multiple Providers

CMS is waiving and modifying waivers under for ICF/IIDs and SNF/NFs.
Specifically, CMS is modifying these requirements as follows:

Alcohol-based Hand-Rub (ABHR) Dispensers: CMS is waiving the requirements for the placement of ABHR dispensers for use by staff and others due to the need for the increased use of ABHR. However, ABHRs contain ethyl alcohol, which is considered a flammable liquid, and there are restrictions on the storage and location of the containers. This includes restricting access by certain patient/resident populations to prevent accidental ingestion.

Due to the increased fire risk for bulk containers (over five gallons) those will still need to be stored in a protected hazardous materials area. In addition, facilities should continue to protect ABHR dispensers against inappropriate use.

Fire Drills: Due to the inadvisability of quarterly fire drills that move and bring staff together, CMS will instead permit a documented orientation training program related to the current fire plan, which considers current facility conditions. The training should instruct employees, including existing, new or temporary employees, on their current duties, life safety procedures and the fire protection devices in their assigned area.

Temporary Construction: CMS is waiving requirements that would otherwise not permit temporary walls and barriers between patients.

Hospital Swing Bed Waiver

The new blanket waivers include a waiver expanding the ability of hospitals to offer long-term care services to patients who do not require acute care but meet the SNF level of care criteria at 42 CFR 409.31. CMS is waiving the eligibility requirements for hospital providers of long-term care services (swing beds) at 42 CFR 482.58(a)(1)-(4) to allow hospitals to establish SNF swing beds payable under the SNF prospective payment system (PPS). This waiver provides additional options for hospitals with patients who no longer require acute care but are unable to find placement in a SNF.

The waiver includes an array of limitations on hospital use of the waiver including applying to the MACs for additional swing beds and attesting:

  1. They have made a good faith effort to exhaust all other options;
  2. There are no skilled nursing facilities within the hospital’s catchment area that under normal circumstances would have accepted SNF transfers, but are currently not willing to accept or able to take patients because of the COVID-19 PHE;
  3. The hospital meets all waiver eligibility requirements; and 
  4. They have a plan to discharge patients as soon as practicable, when a SNF bed becomes available, or when the PHE ends, whichever is earlier.

AHCA/NCAL members concerned about inappropriate hospital use of the waiver should contact their MACs. Find the list of MACs and contact information here.

Guidance on Documentation for Use of COVID-19 SNF Reimbursement Waivers

The CMS waivers also consider requirements that would normally be in place
for providers to receive reimbursement under Medicare or Medicaid. Most
significant were the waiver of the 3-day prior inpatient hospital stay and the 60-
day break in spell-of-illness requirements for SNF Part A benefit eligibility.

Documentation will be critical to demonstrate an organization’s rationale for the
use of the waivers. In a previous update, AHCA/NCAL offered visual flowchart
guidance to help with coverage determinations of these 1135 waivers.
AHCA/NCAL has provided key documentation guidelines for supporting the
employment of these waivers as it is foreseeable that after the emergency
declaration is rescinded, CMS either through the Officer of the Inspector
General (OIG) or through contractors will look to ensure that Medicare dollars
were spent appropriately without fraud, waste and abuse.

CMS Issues Nursing Homes Best Practices Toolkit to Combat COVID-19

CMS released a new toolkit intended to serve as a catalog of resources
dedicated to addressing the specific challenges facing nursing homes as they
combat COVID-19.

CMS says the toolkit provides resources and direction for quality improvement
assistance and can help in the creation and implementation of strategies and
interventions intended to manage and prevent the spread of COVID-19 within
nursing homes. The toolkit outlines best practices for a variety of subjects
ranging from infection control to workforce and staffing. It also provides contact
information for organizations who stand ready to assist with the unique
challenges posed by caring for individuals in long-term care settings.

CMS Issues Nursing Home Reopening Recommendations for State and Local Officials

This week, CMS provided recommendations on a nursing home phased reopening for states. The recommendations cover the following items:
  • Recommendations for testing residents and staff
  • Dedicated space for cohorting residents with COVID-19
  • Criteria for relaxing certain restrictions and mitigating the risk of
  • resurgence
  • Visitation and service considerations
  • Restoration of survey activities
The guidance encourages state leaders to collaborate with the state survey agency and local health departments to decide how these criteria should be implemented. Given the critical importance in limiting COVID-19 exposure in nursing homes, CMS recommends that decisions on relaxing restrictions be made with careful review of the following facility-level, community, and state factors:
  • Baseline test of all residents, weekly testing of all staff, practicing social
  • distancing, and universal source control for residents and visitors (e.g.,
  • face coverings)
  • Status of COVID-19 cases in the local community
  • Status of COVID-19 cases in nursing homes
  • Adequate staffing
  • Access to adequate personal protective equipment (PPE)
  • Local hospital capacity
AHCA/NCAL’s detailed analysis is forthcoming.

Read the press release, guidance and FAQs from CMS.

Economic Impact Payments for Social Security and SSI Beneficiaries with Representative Payees

Dana Ritchie

The Social Security Administration recently issued an update that beneficiaries who have their regular monthly payments managed for them by another person, called a representative payee, will begin receiving their economic impact payments (EIPs) from the IRS in late May.

It is important to note that under Medicaid rules, a stimulus payment is not counted as income. Therefore, receiving a stimulus payment does not change a resident’s monthly payment (often called a ‘patient pay amount’ or ‘share of cost’). The resident pays the same monthly amount to the nursing facility and keeps the stimulus payment for their own use. In addition, the stimulus payment does not count as a Medicaid resource for 12 months. In other words, for the first year, the payment cannot cause you to have ‘too much’ savings.

More details on these payments can be found in this SSA press release. In addition, you might find of assistance two FAQs from the National Center on Law & Elder Rights entitled, “Nursing Home Residents, Medicaid, and Stimulus Checks: What You Need to Know” and “Medicaid Home and Community-Based Services and Stimulus Checks: What You Need to Know.” Questions on this issue can be directed to COVID19@ahca.org.

H.R. 6800, The HEROES Act Passes the House 

On Friday, May 15th, the United States House of Representatives passed H.R. 6800, The HEROES Act, another piece of legislation aimed at addressing the effects of the COVID-19 pandemic. This bill was passed largely along party lines with most Democrats voting for it and Republicans voting against the package. Leader McConnell has stated that he will not bring up this legislation in the Senate. The Senate is likely to craft its own bill. We will continue to work with both chambers and advocate for our priorities during this challenging time.

Of particular note to our sector, below are the provisions found in the bill: 
  • Ensures an additional $100 billion for the provider fund. 
  • Improves the Accelerated and Advance Payment Program that has been critical to keeping providers afloat including lowering interest rates for repayment.
  • Allows facilities with the most losses from this pandemic to be compensated fairly. 
  • Increases the Federal Matching Assistance Percentage (FMAP) by 14 percentage points through June 30, 2021. At a time of financial instability, this would ensure State governments have the resources they need to continue providing critical services.
  • Delays the implementation of the Medicaid Financial Accountability Rule (MFAR) until the end of the emergency period.
  • Requires Medicare’s Quality Improvement Organizations to provide infection control support to nursing homes struggling with COVID-19 outbreaks.
  • Ensures skilled nursing facilities have a means for residents to conduct “televisitation” with loved ones while in-person visits are not possible during the COVID-19 emergency. 
  • Requires public reporting of positive cases in nursing facilities. 
  • Provides $150 million to states to create strike teams if three or more residents or staff are diagnosed with COVID-19 in a 72-hour time period. 
  • Provides a 20 percent per diem increase for facilities with COVID-19 only units.
  • Provides a $13.00 increase in wages for essential workers up to $10,000. 
As the Senate begins to consider this bill, we will keep you updated as to what
the final outcome will be.

AHCA/NCAL Offers New Online Training for Improving Functional Outcomes

Dave Kyllo 

AHCA/NCAL has released a new online training titled Functional Outcomes Improvement and designed for all staff who have a role in improving patient functional outcomes quality and services, including nurses, CNAs, therapists, activities staff and recreational therapists.

This course advances knowledge and skills about functional improvement through an array of learning tools and resources designed to meet the educational needs of various staff and departments. This includes learning about daily care best practices and real-world tools that improve functional outcomes.

The Medicare Payment Advisory Commission (MedPAC), the IMPACT Act, and CMS called for the development of functional improvement measures based on the self-care and mobility sections of the Continuity Assessment Record and Evaluation (CARE) tool.

The program is flexible and can be completed in one sitting or one module at a time. The training is delivered in five modules, including:
  • Module 1 – Explores the connection between functional outcomes and person-centered care, and how utilization of evidence-based pragmatic programs leads toward continuous improvement.
  • Module 2 – Reviews the regulations related to functional outcomes including the CMS Requirements of Participation and how functional improvement impacts reimbursement.
  • Module 3 – Covers best care coordination practices for short- and long-stay patients, including coordinating with therapy processes, and provides an overview of effective restorative nursing programs.
  • Module 4 – Closely examines care practice application and what individuals can do to increase function, team engagement and concludes with a discussion of various quality initiatives that lead to better outcomes.
  • Module 5 – Reviews the tools and resources needed to further functional outcomes improvement approaches to person-centered care.     
The cost for the training program is $199 for AHCA/NCAL members and $650 for non-members and offers 6.5 NAB CE credits for administrators and 6.5 contact hours for nurses through the Iowa Board of Nursing. There is a quiz at the end of four of the five modules and participants must pass a final exam with a score of 80 or higher to receive credit. Click here to register or go to ahcancal.org/functionaloutcomes.

Members will need to login with their AHCA/NCAL usernames and passwords to register. For assistance obtaining AHCA/NCAL usernames and passwords, members should e-mail educate@ahca.org with their name and facility contact information.

NCAL Awards Program: 2020 Nominations are Open!



Know an outstanding assisted living nurse or executive director? Last year, did your community create the best National Assisted Living Week® programming based on the "A Spark of Creativity" theme? Or maybe there is an unlicensed caregiver or someone in the dietary, housekeeping, or maintenance departments who goes above and beyond the call of duty? If you answered yes, then check out NCAL’s 2020 Awards Program. This program gives awards in four categories:

  • Administrator of the Year
  • Nurse of the Year
  • Noble Caregiver in Assisted Living
  • National Assisted Living Week Programming
Before submitting your nomination, make sure you have all the necessary components. To nominate, the following items are required:
  • Administrator and Nurse of the Year nominations: 500-word essay and candidate’s resume
  • Noble Caregiver in Assisted Living nominations: 500-word essay
  • National Assisted Living Week Programming nominations: 500-word essay, activity calendar from the week, and pictures from the week.

   
For more information and to submit a nomination, please visit www.ncal.org/awards. Completed nominations must be submitted no later than Friday, July 10, 2020.

Help recognize those that demonstrate outstanding service!

Jan Thayer Pioneer Award Nominations Open!



Nominations are now open for NCAL’s 2020 Jan Thayer Pioneer Award. ​The award recognizes an individual who has moved the senior care profession forward, positively affecting the lives of those served and those who serve. Recipients must demonstrate dedication, leadership and considerable contributions to the senior care profession.

Nominations must be submitted online and include a 500-word or less essay, along with a copy of the candidate’s resume. Nominators must be members of AHCA/NCAL; however, candidates are not required to be members. All nominations must be received by July 10, 2020. The recipient is selected by the NCAL Executive Committee.

The Jan Thayer Pioneer Award is posthumously named after the first Board Chair of NCAL Jan Thayer. A provider for more than 25 years, Thayer owned and operated Riverside Lodge in Grand Island, Nebraska. She also founded and headed up the Excel Development Group, which owned and managed retirement communities throughout the Midwest and employed hundreds.

This is the sixth year NCAL is honoring an individual in the assisted living profession. The award was bestowed to Elizabeth Blankenship last year.

Tuesday, May 19, 2020

Employee Retention Credit Available for Businesses Affected by COVID-19

Dana Ritchie 

The IRS recently shared in a COVID tax email update information around the employee retention credit, which is designed to encourage businesses to keep employees on their payroll. The amount of the credit is 50% of qualified wages paid up to an annual limit of $10,000, which equals a maximum credit amount of $5,000 for each employee for the year.

Eligible employers are employers who operate a trade or business and has experienced one of these:

  • Fully or partially suspended operations because of a government order due to COVID-19
  • A significant decline in gross receipts in a calendar quarter when compared to 2019

How is the credit figured?

  • The amount of the credit is half of qualifying wages paid up to $10,000 for all calendar quarters. The maximum credit for any employee is $5,000 for the year.
  • Wages paid between March 12, 2020, and January 1, 2021 are eligible.
  • Wages are not limited to cash payments. They also include a portion of employer-provided health care costs.

Which wages qualify?

Qualified wages are based on the business’s average number of full-time employees in 2019.

  • Small employers, those that had 100 or fewer employees, may receive the credit for wages paid to employees whether or not they are providing services to the employer.
  • Large employers, those that had more than 100 employees, may only receive the credit for wages paid to employees for time the employees are not providing services to the employer.

If an employer is eligible due to a full or partial suspension of operations, only wages paid while operations are suspended count as qualified wages.

How do eligible employers get the credit?

Employers must report their qualified wages on their federal employment tax returns, usually Form 941, Employer's Quarterly Federal Tax Return.

They can reduce their required deposits of payroll taxes withheld from employees’ wages by the amount of the credit. They can also request an advance of the employee retention credit by submitting Form 7200. Eligible employers may use the employee retention credit with other relief such as, payroll tax deferral which may affect deposits and advances. More Information can be found on the Coronavirus page of IRS.gov and here: About Form 7200.

Enhanced Opportunity for Submission of 2nd Level Appeals, Reconsiderations

Dan Ciolek

On May 7, 2020, the Centers of Medicare and Medicaid Services (CMS) posted enhanced flexibilities for providers to submit 2nd level Medicare Fee-For-Service (FFS) claim appeals (reconsiderations) to Qualified Independent Contractors (QICs). Specifically, CMS has established alternative communication mediums for stakeholders to submit reconsideration requests and related documentation to the QIC. The websites for the respective QIC jurisdictions contain instructions to stakeholders for electronic (e.g., fax or portal) submission of reconsideration requests or documentation. Guidance regarding the options for submitting reconsiderations and related documentation is also summarized by QIC jurisdiction as posted here

Note: implementation of these alternative mechanisms does not preclude providers from ongoing submission of 2nd level appeals via hard copy mail. Please share this information with your claim appeals staff.

CMS Issues Limited MDS Updates to OBRA Assessments for Medicaid Case Mix States Using PDPM

Dan Ciolek

In response to State Medicaid Agency and stakeholder requests, the Centers for Medicare and Medicaid Services (CMS) has updated the MDS 3.0 item sets (version 1.17.2) and related technical data specifications. These changes will be effective October, 1 2020 and will support the calculation of Patient Driven Payment Model (PDPM) payment codes on Omnibus Budget Reconciliation Act (OBRA) assessments when not combined with the 5-day Skilled Nursing Facility Prospective Payment System (SNF PPS) assessment, specifically the OBRA comprehensive (NC) and OBRA quarterly (NQ) assessment item sets, which was not possible with item set version 1.17.1. This will allow State Medicaid Agencies to collect and compare RUG-III/IV payment codes to PDPM ones and thereby inform their future payment models. In other words, these changes will only impact providers in states where the state requires the reporting of PDPM HIPPS codes on OBRA assessments for Medicaid purposes.

Below is a table summarizing the changes to the MDS OBRA item sets effective October 1, 2020 (highlighted in yellow and italicized:


The changes to the technical data specifications that support these modifications (used primarily by software vendors) are contained in the Errata v3.00.4. CMS has indicated to AHCA that additional training resources related to these changes will be made available prior to implementation, particularly for Medicaid-only providers in states that may not be familiar with the PDPM MDS coding requirements. 

Providers should confirm with your State Medicaid Agency if your State will be requiring the calculation of the PDPM payment codes on the OBRA assessments when not combined with a 5-day SNF PPS assessment.

AHCA’s Online Trainings Build SNF ICD-10 Coding Proficiency

Dave Kyllo 

AHCA has partnered again in 2020 with the American Health Information Management Association (AHIMA) to offer two updated online in-depth ICD-10 trainings and two new 2.5-hour update trainings for staff with ICD-10 coding experience/knowledge.

The Patient Driven Payment Model (PDPM) relies on rapid and accurate patient assessment and diagnosis, and on MDS and ICD-10 coding to determine payments for each SNF patient.  Incorrect or insufficient coding can significantly impact the payment rate for each patient.

More than 40,000 ICD-10 codes can be used to report the primary reason for a SNF stay on the PDPM MDS assessment. Building ICD-10 coding proficiency and capacity are essential to ensure proper reimbursement for needed care and services.

The 2020 ICD-10 trainings are:
  • AHCA/AHIMA ICD-10 Training for PDPM – Full Length Coding and Documentation Training 16 CNEs for nurses or 16 AHIMA CEUs for Health Information Management (HIM) professionals upon completion. Intended for New SNF Staff (or staff interested in a full re-fresher) with Responsibilities for MDS and Billing. $499 AHCA Member | $599 Non-Member
  • AHCA/AHIMA ICD-10 Training for PDPM– Full Length Training for Non-Coding Roles 4 CNEs or 4.5 NAB administrator CEs or 4 AHIMA CEUs upon completion. Intended for New SNF Staff (or staff interested in a full re-fresher) Who Need Knowledge About ICD-10-CM Coding to Support Other SNF Staff (e.g., Administrators, Regional Managers, etc.)  $199 AHCA Member | $249 Non-Member
  • AHCA/AHIMA ICD-10 Coding Updates for PDPM and Expanded Case Examples -- Updates Only Version  2.5 CNEs or 3 NAB administrator CEs or 2.5 AHIMA CEUs upon completion. Short Update Training on CMS Changes to PDPM ICD-10-CM Codes Intended for Experienced  SNF Staff with Responsibilities for MDS and Billing. $99 AHCA Member | $149 Non-Member  
  • AHCA/AHIMA ICD-10 General Updates for PDPM and Expanded Case Examples for Non-Coding Roles -- Updates Only Version 2 CNEs or 2.25 NAB administrator CEs or 2 AHIMA CEUs upon completion. Short Update Training on CMS Changes to PDPM ICD-10-CM Codes Intended for Experienced SNF Staff Who Need Knowledge About ICD-10-CM Coding to Support Other SNF Staff (e.g., Administrators, Regional Managers, etc.)  $99 AHCA Member | $149 Non-Member   

Participants must pass a short test at the end of each module for all courses with a score of 70 or greater to receive CNEs/CEUs.

To register for any of the four ICD-10 courses, go to ahcancal.org/icd10.

Members will need to login with their AHCA/NCAL usernames and passwords to register. For assistance obtaining AHCA/NCAL usernames and passwords, members should e-mail educate@ahca.org with their name and facility contact information.



 

AHCA & CMS Recommend That Skilled Nursing Facilities Have Two Specially Trained Infection Preventionists

Dave Kyllo 

AHCA/NCAL’s expanded version of its popular Infection Preventionist Specialized Training (IPCO Version 2) in now available. The online training is recommended for individuals responsible for infection prevention and control in all long term care settings, including assisted living.

Phase III Requirements of Participation took effect November 28, 2019 and mandate that every nursing facility have a designated and specially trained Infection Preventionist who is running a comprehensive infection prevention and control program.  The training is also highly recommended for assisted living communities because they care for a similar population and can face similar infection risks.

AHCA has long recommended that each skilled nursing facility train at least two Infection Preventionists through AHCA’s IPCO training program should one Infection Preventionist leave the facility or be unavailable. On its May 13 weekly call for nursing homes, CMS also recommended that skilled nursing facilities have two Infection Preventionists for the same reasons.

IPCO Version 2 is designed to train Infection Preventionists and is approved for 25 ANCC contact hours. The online course is also now approved for 22 NAB CEUs for Administrators. AHCA/NCAL recognizes Administrators will not serve as designated Infection Preventionists but recommends that Administrators consider taking the course to gain a deeper understanding of infection prevention and control in the overall operation of a nursing facility as this is a high target area for survey and liability.

IPCO Version 2 includes:
    • Updated regulatory requirements and added course content, including: 
    • Multi-drug Resistant Organisms (MDROs) and Enhanced Barrier Precautions (EBP)
    • Candida Auris
    • Water management
    • COVID-19
  • Bonus Content – All persons who register for IPCO Version 2 receive additional non-CE approved content. Topics include Interim COVID-19 Guidance, and courses on PPE and N-95 mask use.  
The registration fee is $450 for AHCA/NCAL members and $650 for non-members. There are no refunds and no transfers. Registrants have one year to complete the course. Payment and registration are made online at ahcancalED. Discounted group purchase rates are available for groups of 25 or more by contacting educate@ahca.org.

Note that while CDC/CMS does offer a free infection prevention training course, AHCA’s IPCO Version 2 training is far more comprehensive and includes updated information that is taught by experts with real-life practical long term care experience.

Members will need to login with their AHCA/NCAL usernames and passwords to register for IPCO Version 2. For assistance obtaining AHCA/NCAL usernames and passwords, members should e-mail educate@ahca.org with their name and facility contact information.


Wednesday, May 13, 2020

Senators Call For $2 Billion In New Federal Funding To Help Health Care Providers Expand Telehealth Services During Pandemic

Dana Ritchie 

On May 11, U.S. Senator Brian Schatz (D-Hawai‘i) led a bipartisan group of senators to urge the leadership of both the Senate and House of Representatives to include $2 billion in the next coronavirus relief package to help health care providers expand telehealth services by improving their access to broadband. “The coronavirus pandemic has dramatically increased the need to expand telehealth,” the senators wrote in a letter to Senate Majority Leader Mitch McConnell (R-Ky.), House Speaker Nancy Pelosi (D-Calif.), Senate Minority Leader Chuck Schumer (D-N.Y.), and House Minority Leader Kevin McCarthy (R-Calif). “It is imperative that Congress act to ensure our front-line responders have the tools they need to combat this deadly virus.”

The Schatz press statement noted that, “Telehealth allows health care providers to treat patients safely without putting themselves or their patients at risk of contracting COVID-19 and has been recommended by the Centers for Disease Control and Prevention. However, many providers – especially in rural and hard-to-reach communities – lack the resources to handle this increase in demand for telehealth services. The senators are calling for $2 billion in additional funding to the Rural Health Care (RHC) Program, the only federal program that supports broadband deployment at urban and rural health care provider locations. These new funds would expand the RHC Program to support non-rural and mobile health care providers, eliminate administrative red tape slowing down the process of obtaining broadband connectivity, and provide more resources to help providers increase their broadband capacity.”

As noted in previous AHCA communication, AHCA supported H.R. 6474, the Healthcare Broadband Expansion During COVID-19 Act, which is a bipartisan bill to provide $2 billion to expand telehealth and high-quality internet connectivity at public and nonprofit healthcare facilities, including mobile clinics and temporary health facilities deployed to respond to the coronavirus pandemic. The House Health Subcommittee Chairwoman Anna G. Eshoo (D-CA) and Representative Don Young (R-AK) introduced this legislation.

Further information on this issue, including the Senate letter noted above, can be found here.

2020 AHCA/NCAL Award Nominations Are Open!

Over the past few months, long term care facilities have been faced with extreme challenges and difficulties due to the COVID-19 pandemic.

In light of our current state of affairs, now, more than ever, is the time to recognize the extraordinary staff and volunteers who have shown courage even in the midst of COVID-19 and who continue to do the right thing in the right way.

The AHCA Awards Program has been revamped to recognize people in different roles within skilled nursing, and still honors individuals who are committed to improving the quality of life for residents. Categories include:

  • AHCA Administrator of the Year
  • AHCA Program of the Year
  • AHCA Noble Caregiver
  • Volunteer of the Year
Nomination packets and guidelines are available on AHCA's website now.

The Mary K. Ousley Champion of Quality Award recognizes an individual who has made significant national contributions in advancing quality performance in long term and/or post-acute care in skilled nursing or assisted living settings. Nominations must be submitted online here.

The Jan Thayer Pioneer Award recognizes an individual who has moved the senior care profession forward, positively affecting the lives of those served and those who serve. Recipients must demonstrate dedication, leadership and considerable contributions to the senior care profession. Nominations can be submitted online here.

The NCAL Awards Program identifies assisted living employees from around the country who demonstrate exemplary work within the profession. This program gives awards in four categories:

  • Administrator of the Year
  • Nurse of the Year
  • Noble Caregiver in Assisted Living
  • National Assisted Living Week® Programming

Read the full Rules & Guidelines for the 2020 NCAL Awards Program and submit a nomination online at www.ncal.org/awards.

Nominations for all AHCA/NCAL Awards programs must be submitted no later than Friday, July 10, 2020.

Tuesday, May 12, 2020

NHSN Reporting Recap and Next Steps

Nursing centers who are still waiting for access to the National Healthcare Safety Network (NHSN) COVID-19 reporting module are encouraged to document all attempts to gain access to NHSN including any email communications you have with the NHSN help desk. Centers trying to register for NHSN continue to run into enrollment delays and lag time between initial registration process and actually gaining access to the reporting system. The delays may put centers at risk for non-compliance. Centers should keep documentation to track and log every attempt to register and gain access to NHSN, email communications to NHSN help desk, and communication responses from NHSN help desk dates to provide to state surveyors and the Centers for Medicare and Medicaid Services (CMS) in the event that your center is not granted access by the end of the grace period.

On May 6, CMS released a QSO memo on the Interim Final rule requiring nursing centers to report to NHSN which went into effect on May 8th. Facilities are required to submit their first set of data by 11:59pm on Sunday, May 17 to NHSN Long-Term Care Facility COVID-19 Module. CMS provided facilities with an initial two-week grace period to begin reporting cases in the NHSN system which ends at 11:59pm on May 24. Centers who do not begin reporting by 11:59pm on May 31 will receive a warning letter reminding them to begin reporting the required information to the NHSN COVID-19 Module. For centers who fail to report by 11:59pm on June 7, CMS will impose a per day (PD) CMP of $1,000 for failure to report that week. Each subsequent week that the facility fails to submit the required report will result in an additional one-day PD CMP imposed at an amount increased by $500. The memo also included information about two F-tag citations (F884 – COVID-19 Reporting to CDC and F885 – COVID-19 Reporting to Residents, their Representatives, and Families).

AHCA recommends accurately reporting the staffing and personal protective equipment (PPE) situation at nursing homes based on normal standards and guidance for PPE and staffing, not utilizing conservation guidance. Federal and state governments will use this data to hold nursing homes accountable for care and services provided and to identify who needs additional resources. It is important that the data reported to NHSN gives an accurate picture of staffing and PPE as well as the other areas collected in NHSN. Nursing homes should keep documentation of their efforts to secure more PPE as well as staffing. You should also report to your local and state health departments that you are employing contingency and crisis strategies to conserve PPE and staffing.

As a reminder, the new rule requiring nursing centers to report to NHSN is optional for assisted living communities.  Assisted living communities should follow specific state reporting requirements and notifications.

The four NHSN data collection pathway forms are:

Attestation Period Extended for CARES Act Provider Relief Funds

Today, the U.S Department of Health and Human Services (DHHS) announced that the attestation window and related acceptance of Terms and Conditions has been extended to 45 days, formerly 30 days, from the date a provider received a payment to attest to and accept the Terms and Conditions or return the funds. Members will need to identify the date of their initial funding relief payment and identify their new attestation and Terms and Conditions acceptance date based on the extension. In the press release, DHHS offers an example of how the extension of the window will be operationalized.

Shortly after announcing the extension of the provider-specific attestation period, DHHS released an updated set of FAQs. Members should review the FAQs in detail and compare these with the Terms and Conditions. Below are preliminary highlights. Additional AHCA/NCAL assessment will be provided tomorrow.

  • Additional Funding is Available to Targeted and General Allocations. This point has been a notable point of confusion. DHHS now states, “Any provider who has already received a payment from the Provider Relief Fund … should apply for additional funding.” 
  • General Fund Allocation Updates. Skilled Nursing Facilities (SNFs) are eligible for general fund awards. Below is a list of new or updated: 
    • Higher Payment Than Expected. DHHS describes what a provider should do if they believe payment is greater than expected or received in error; 
    • Description of Recoupment. DHHS notes that in general the Department “does not intend to recoup funds as long as a provider’s lost revenue and increased expenses exceed the amount of Provider Relief funding a provider has received. Additionally, in the General Allocation portion of the website, DHHS has added text bolstering this point and noting “there will be significant anti-fraud and auditing work done by HHS, including the work of the Office of the Inspector General.” 
    • Expenditure of Funds on Individuals with Possible, Presumptive, and Actual Cases of COVID-19. DHHS notes that Provider Relief Funds may be used for possible, presumptive, and actual COVIDpositive patients and discusses each term. Terms and Conditions Updates. DHHS offers additional details on how it will monitor adherence to the 
  • Terms and Conditions and offers detail on certain provisions. The majority of the updates focus on the Targeted Allocations such as High Impact and Rural Allocations. 
  • Rejecting Funds. DHHS notes that “providers may return their General Distribution payment by going into the attestation portal indicate they are rejecting the funds. The CARES Act Provider Relief Fund Payment Attestation Portal will guide providers through the attestation process to reject the funds.” AHCA/NCAL assumes DHHS’ intent is within 45 days but will seek clarification. 
  • Reporting Requirements. The Department notes it will be posting specific reporting requirements in the coming weeks. 
AHCA/NCAL will continue to submit questions and examples of challenging fund scenarios to DHHS including Change in Ownership (CHOW), Tax Identification Number (TIN) aggregation, disaggregation, or lack of TIN arrangements, additional questions about financial terminology and use of tax filing data for validation. 

PPE Supplier List

Knowing whether a Personal Protective Equipment (PPE) supplier is reliable is challenging these days with all the pop-up PPE suppliers and PPE scams. To assist members, AHCA/NCAL has developed a list of PPE suppliers that have recently served long term care providers. The list is not an endorsement or seal of approval of any particular PPE supplier, but can be used as a resource when PPE is not available through their ordinary supply chains.

Members should keep in mind that PPE demand currently far exceeds PPE supply. Suppliers are facing unprecedented challenges obtaining PPE, so the suppliers on this list may not have PPE at the time they are contacted. These PPE suppliers are doing their best to fill orders as PPE shipments arrive or their PPE is manufactured. If a supplier is out of stock, ask when to check back.

This list will be updated as more PPE suppliers are identified that have successfully delivered PPE supplies to AHCA/NCAL members during the pandemic. 

White House Tells States to Test All Nursing Home Residents & Staff

Yesterday, the White House recommended to state governors to test all residents and staff in nursing homes across the country within the next two weeks. This is not an order from the federal government and as of May 12 no specific written recommendation has been made. However, we expect to see states develop plans to put these recommendations into place to the extent feasible. Members should review AHCA/NCAL’s testing guidance.

Providers should prepare to meet this requirement by contacting their state health department to seek information on preferred vendors, testing protocols, availability of tests and reimbursement for testing. You should also ask the state health department what to do and document if a resident or staff person refuses to be tested. Document all your communications with the state health department and the steps you take as a result.

In absence of direction from the state health department, facilities can refer to AHCA/NCAL’s list of vendors who can provide testing in the long term care setting. This list is continually updated as new vendors and testing opportunities are available, so please check back frequently.

When testing residents and staff, providers must use PCR tests and should not use antibody tests in place of PCR tests unless instructed by your state officials. Antigen tests are new to the market and while we believe they can be used to comply with this new guidance, their availability is still very limited.

Residents who test positive for COVID-19 must be isolated and wear a source control mask until placed in isolation. Providers are encouraged to follow AHCA/NCAL guidance on steps to take when COVID-19 gets in.

Providers should also explore cohorting with other positive residents, if possible. Providers should review the CDC Return to Work Criteria guidance for considerations for permitting health care providers (HCP) to return to work without meeting all return to work criteria outlined. In addition, providers should refer to CDC’s Strategies to Mitigate Healthcare Personnel Staffing Shortages for information on contingency and crisis strategies should a large number of your staff test positive. 

AHCA/NCAL is also seeking feedback from members on COVID-19 test availability and use in both skilled nursing and assisted living settings. Information from this survey will help identify challenges and advocate for more availability and clearer guidance on how testing should be used and reimbursed on a national level.

Please take a few minutes to complete the survey by Wednesday, May 13 (11:59 PM EDT). 

CMS to Fix PDPM Variable Per Diem Glitch

SNF PPS Part A claims were not being paid day-1 variable per diem rates when a beneficiary switched from Medicare Advantage (MA) to fee-for-service Medicare Part A during a stay. AHCA reported to CMS that this was inconsistent with current policy.

CMS agreed with AHCA and on May 8 published a change request to the Medicare Administrative Contractors (MACs) to update the claims processing systems retroactive to October 1, 2019. A summary of the changes is posted in this MLN Matters article. Although this is retroactive, the systems changes will not occur until October 5, 2020.

Providers should notify billing staff that the MACs will adjust any improperly adjusted SNF PPS claims related to a beneficiary switch from MA to fee-for-service during a stay ONLY IF BROUGHT TO THEIR ATTENTION, so that the prior days count is corrected to exclude the MA days.

Many Part B Therapy Code Edits Removed

As part of a recent COVID-19 related update to National Correct Coding Initiative (CCI) files, CMS announced the removal of many problematic claim coding edits related to Medicare Part B PT, OT, and SLP services. The changes are effective for dates of service beginning April 1, 2020. Medicaid and most private insurance also follow the CCI edit policies. Provider billing staff should review the updated files available on the PTP Coding Edit webpage and the Quarterly PTP and MUE Version Update Changes webpage.

Expanded Infection Preventionist Online Training Includes New COVID-19 Content

Dave Kyllo

AHCA/NCAL’s new and expanded version of its popular Infection Preventionist Specialized Training (IPCO Version 2) in now available. The online training is recommended for individuals responsible for infection prevention and control in all long term care settings, including assisted living.

Phase III Requirements of Participation took effect November 28, 2019 and mandate that every nursing facility have a designated and specially trained Infection Preventionist who is running a comprehensive infection prevention and control program. AHCA recommends that each skilled nursing facility train at least two Infection Preventionists through AHCA’s IPCO training program should one Infection Preventionist leave the facility. The training is also highly recommended for assisted living communities because they care for a similar population and can face similar infection risks. 

IPCO Version 2 is designed to train Infection Preventionists and is approved for 25 ANCC contact hours. The online course is also now approved for 22 NAB CEUs for Administrators. AHCA/NCAL recognizes Administrators will not serve as designated Infection Preventionists but recommends that Administrators consider taking the course to gain a deeper understanding of infection prevention and control in the overall operation of a nursing facility as this is a high target area for survey and liability. 

IPCO Version 2 includes:

  • Updated regulatory requirements and added course content, including: 
    • Multi-drug Resistant Organisms (MDROs) and Enhanced Barrier Precautions (EBP)
    • Candida Auris
    • Water management
    • COVID-19
  • Bonus Content – All persons who register for IPCO Version 2 receive additional non-CE approved content. Topics include Interim COVID-19 Guidance, and courses on PPE and N-95 mask use.  
The registration fee is $450 for AHCA/NCAL members and $650 for non-members. There are no refunds and no transfers. Registrants have one year to complete the course. Payment and registration are made online at ahcancalED. Discounted group purchase rates are available for groups of 25 or more by contacting educate@ahca.org

Note that while CDC/CMS does offer a free infection prevention training course, AHCA’s IPCO Version 2 training is far more comprehensive and includes updated information that is taught by experts with real-life practical long term care experience. 

Members will need to login with their AHCA/NCAL usernames and passwords to register for IPCO Version 2. For assistance obtaining AHCA/NCAL usernames and passwords, members should e-mail educate@ahca.org with their name and facility contact information. 

Need Continuing Education Credits? AHCA/NCAL Delivers 70 Quality Sessions in One Affordable Package

Dave Kyllo

AHCA/NCAL has the online courses to help administrators, directors, and nurses meet their continuing education (CE) needs! The AHCA/NCAL 2019 Convention Education sessions are available to members and non-members in a package offering 70 online NAB and ANCC (nurses) approved courses. 

There are more than enough online courses in the package to meet most license requirements. Topics include those related to clinical practice, workforce, assisted living, technology, dementia care, and more!

The package is online, available 24-hours a day and the interface is easy. After purchasing the package, you choose a course, view the webinar, take and pass the quiz, print your CE certificate, and then self-report the course information to your NAB profile or nurse board.

The package costs $200. Once the package is purchased, access to the courses will be available until September 1, 2020. The package is for individual use only and access cannot be shared. Single courses are not available. You can access the package here.

Updated List of Excluded Individuals and Entities (LEIE) Database File

The US Department of Health and Human Services, Office of Inspector General (OIG) has released its updated List of Excluded Individuals and Entities (LEIE) database file, which reflects all OIG exclusions and reinstatement actions up to, and including, those taken in March 2020. This new file replaces the updated LEIE database file available for download last month. Individuals and entities that have been reinstated to the federal health care programs are not included in this file.

The updated files are posted on OIG’s website at http://www.oig.hhs.gov/exclusions/exclusions_list.asp, and healthcare providers have an “affirmative duty” to check to ensure that excluded individuals are not working in their facilities or face significant fines.

Instructional videos explaining how to use the online database and the downloadable files are available at http://oig.hhs.gov/exclusions/download.asp.

As a best practice, long term care providers should check the LEIE on a regular basis.

Wednesday, May 6, 2020

COVID-19 Reporting to NHSN: What do you need to know?

On April 28, the Centers for Disease Control and Prevention (CDC) released the National Healthcare Safety Network (NHSN) COVID-19 reporting module for long term care facilities. Currently enrolled facilities will see the new module when they log in. Centers who were not previously enrolled in NHSN will be required to go through an expedited enrollment process.

The Centers for Medicare & Medicaid Services (CMS) issued an interim final rule, effective May 1, which establishes explicit reporting requirements for long-term care (LTC) facilities to report information related to COVID-19 cases among facility residents and staff to the NHSN COVID-19 module. The first reporting is to be submitted by May 8. AHCA is advocating that there be a grace period for enforcement of this rule given the technical complexities and quantity of information that must be submitted to CDC for NHSN COVID-19 reporting. 

NHSN COVID-19 reporting is not required but optional for assisted living communities. Assisted living communities should follow specific state reporting requirements.

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.

The CDC recommends daily reporting to NHSN. This will provide the timeliest data which will be informative and provide situational awareness at both state and national levels. The CDC recognizes that this may not be possible and requests that at a minimum the center should enter data at least once a week and at the same time.

Providers are running into delays while trying to complete the NHSN registration process. The CDC has reported a backlog of providers needing assistance with registering for NHSN. In some instances, the CDC reports that it may take 5-7 days to receive a response due to the sheer numbers of facilities trying to register for NHSN. 

While waiting for the registration process to complete, you should download now the four data collection pathway forms and accompanying instructions to start collecting the data that you will be uploading to NHSN once registration process is complete. It is extremely important to download, and refer to, the instructions page for each of the four data collection pathways. Refer to the definitions of each term prior to completing the data collection form.

The four data collection pathway forms are:


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. 

Updated ICD-10 Trainings & New ICD-10 Update Courses Available for SNFs

Dave Kyllo

AHCA has partnered again in 2020 with the American Health Information Management Association (AHIMA) to offer two updated online in-depth ICD-10 trainings  and two new 2.5-hour update trainings for staff with ICD-10 coding experience/knowledge. 

The Patient Driven Payment Model (PDPM) relies on rapid and accurate patient assessment and diagnosis, and on MDS and ICD-10 coding to determine payments for each SNF patient.  Incorrect or insufficient coding can significantly impact the payment rate for each patient. 

More than 40,000 ICD-10 codes can be used to report the primary reason for a SNF stay on the PDPM MDS assessment.  Building ICD-10 coding proficiency and capacity are essential to ensure proper reimbursement for needed care and services. 

The 2020 ICD-10 trainings are:

  • AHCA/AHIMA ICD-10 Training for PDPM – Full Length Coding and Documentation Training 16 CNEs for nurses or 16 AHIMA CEUs for Health Information Management (HIM) professionals upon completion. Intended for New SNF Staff (or staff interested in a full re-fresher) with Responsibilities for MDS and Billing.   $499 AHCA Member | $599 Non-Member  
  • AHCA/AHIMA ICD-10 Training for PDPM– Full Length Training for Non-Coding Roles 4 CNEs or 4.5 NAB administrator CEs or 4 AHIMA CEUs upon completion. Intended for New SNF Staff (or staff interested in a full re-fresher) Who Need Knowledge About ICD-10-CM Coding to Support Other SNF Staff (e.g., Administrators, Regional Managers, etc.)   $199 AHCA Member | $249 Non-Member   
  • AHCA/AHIMA ICD-10 Coding Updates for PDPM and Expanded Case Examples  Updates Only Version 2.5 CNEs or 3 NAB administrator CEs or 2.5 AHIMA CEUs upon completion. Short Update Training on CMS Changes to PDPM ICD-10-CM Codes Intended for Experienced  SNF Staff with Responsibilities for MDS and Billing.  $99 AHCA Member | $149 Non-Member   
  • AHCA/AHIMA ICD-10 General Updates for PDPM and Expanded Case Examples for Non-Coding Roles -- Updates Only Version 2 CNEs or 2.25 NAB administrator CEs or 2 AHIMA CEUs upon completion. Short Update Training on CMS Changes to PDPM ICD-10-CM Codes Intended for Experienced SNF Staff Who Need Knowledge About ICD-10-CM Coding to Support Other SNF Staff (e.g., Administrators, Regional Managers, etc.)   $99 AHCA Member | $149 Non-Member   
Participants must pass a short test at the end of each module for all courses with a score of 70 or greater to receive CNEs/CEUs.

To register for any of the four ICD-10 courses, go to ahcancal.org/icd10.

Members will need to login with their AHCA/NCAL usernames and passwords to register.  For assistance obtaining AHCA/NCAL usernames and passwords, members should e-mail educate@ahca.org with their name and facility contact information. 

Registration Opens for New, Expanded Infection Preventionist Online Training

Dave Kyllo

AHCA/NCAL has a new and expanded version of its popular Infection Preventionist Specialized Training (IPCO Version 2), and registration is open for the online training. 

Phase III Requirements of Participation took effect November 28, 2019 and mandate that every nursing facility have a designated and specially trained Infection Preventionist who is running a comprehensive infection prevention and control program. AHCA recommends that each skilled nursing facility train at least two Infection Preventionists through AHCA’s IPCO training program should one Infection Preventionist leave the facility. The training is also highly recommended for assisted living communities because they care for a similar population and can face similar infection risks. 

IPCO Version 2 is designed to train Infection Preventionists and is approved for 25 ANCC contact hours. The online course is also now approved for 22 NAB CEUs for Administrators. AHCA/NCAL recognizes Administrators will not serve as designated Infection Preventionists but recommends that Administrators consider taking the course to gain a deeper understanding of infection prevention and control in the overall operation of a nursing facility as this is a high target area for survey and liability. 

  • IPCO Version 2 includes:Updated regulatory requirements and added course content, including: 
    • Multi-drug Resistant Organisms (MDROs) and Enhanced Barrier Precautions (EBP)
    • Candida Auris
    • Water management
    • COVID-19
  • Bonus Content – All persons who register for IPCO Version 2 receive additional non-CE approved content. Topics include Interim COVID-19 Guidance, and courses on PPE and N-95 mask use.  

The registration fee is $450 for AHCA/NCAL members and $650 for non-members. There are no refunds and no transfers. Registrants have one year to complete the course. Payment and registration are made online at ahcancalED. Discounted group purchase rates are available for groups of 25 or more by contacting educate@ahca.org

Note that while CDC/CMS does offer a free infection prevention training course, AHCA’s IPCO Version 2 training is far more comprehensive and includes updated information that is taught by experts with real-life practical long term care experience. 

Members will need to login with their AHCA/NCAL usernames and passwords to register for IPCO Version 2. For assistance obtaining AHCA/NCAL usernames and passwords, members should e-mail educate@ahca.org with their name and facility contact information. 

New CE Webinar Focuses on an Evidence-Based Approach for Improving Mobility

Dan Ciolek

AHCA has a new webinar available titled Getting Older is not for the Weak: An Evidence-Based Approach for Improving Mobility that offers 1.25 CEs upon successful completion of a short quiz at the conclusion of the webinar.

In this training module, the RESTORE team, a collaborative group of researchers, educators, and professionals within the University of Colorado Physical Therapy Program, will share an approach for helping providers integrate the latest evidence-based rehabilitation strategies into routine practice.

The Getting Older is not for the Weak session is free with a PDPM Academy 2020 subscription.  AHCA SNF provider members can still register for the AHCA PDPM Academy 2020 Subscription – Building Optimal Operational Capacities©.  This exclusive “SNF provider member only” subscription package includes:

  • Seven pre-recorded one-hour educational webinars with 1.25 NAB continuing education (CE) credits and accompanied by AHCA-developed guidance toolkits and other resources covering these topics:
    • Holistic person-centered care planning
    • Evidence-based approaches for improving mobility
    • Effective care transitions at admission and discharge
    • Trend Tracker and other sources to monitor the quality impact of PDPM
    • Managing residents with complex nursing and NTA needs
    • Restorative nursing and skilled maintenance nursing and therapy
    • One additional CE webinar (topic to be announced in the future)
  • Five live PDPM Academy Open Discussion Forums: (On-demand recordings of these forums are available to Subscribers)
  • Access to AHCA’s complete library of 2019 and 2020 PDPM Academy materials 
The 2020 subscription fee is $299 per individual and is available only to AHCA SNF provider members (or individual contracted employees if registering through the AHCA provider member).  The materials, toolkits, forums and webinars in the AHCA PDPM Academy 2020 Subscription package come from the nation’s top experts and are hundreds of dollars less than what private consultants are charging.

The Getting Older is not for the Weak session  can also be purchased a la carte. The a la carte registration price per individual for each PDPM Academy 2020 CE session is $150 for AHCA members and $650 for non-members.  The complete collection of PDPM Academy 2020 CE sessions will be held throughout 2020.  As the sessions are completed, they will be available for purchase here: https://educate.ahcancal.org/PDPMCEWebinars.

To access ahcancalED and register for an AHCA PDPM Academy 2020 Subscription, members need to login with their AHCA/NCAL usernames and passwords.  For assistance obtaining AHCA/NCAL usernames and passwords, please e-mail educate@ahca.org with your name and facility contact information.