Tuesday, June 30, 2020

AHCA/NCAL’s Infection Preventionist Training Works for Assisted Living Settings Too

Dave Kyllo

AHCA/NCAL’s expanded version of its popular Infection Preventionist Specialized Training (IPCO Version 2) is recommended for individuals responsible for infection prevention and control in all long term care settings, including assisted living. While designed to train SNF Infection Preventionists, the training is equally effective for assisted living communities because they care for a similar population and can face similar infection risks. 

IPCO Version 2 is approved for 25 ANCC contact hours.  The online course is also now approved for 22 NAB CEUs for Administrators.  AHCA/NCAL recognizes Administrators and Directors will not serve as designated Infection Preventionists but recommends that Administrators and Directors 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.

CMS Updates ABN Form for Medicare Services


The Centers for Medicare and Medicaid Services (CMS) recently updated the Advance Beneficiary Notice of Noncoverage (ABN), Form CMS-R-131, which is issued by SNF and other providers submitting claims for Medicare items and services to beneficiaries in situations where Medicare payment is expected to be denied. The ABN is issued in order to transfer potential financial liability to the Medicare beneficiary in certain instances. Guidelines for issuing the ABN can be found beginning in Section 50 in the Medicare Claims Processing Manual, 100-4, Chapter 30. SNFs issue the ABN to transfer potential financial liability for items/services expected to be denied under Medicare Part B only. The updated ABN, Form CMS-R-131, and form instructions have been approved by the Office of Management and Budget (OMB) for renewal. The use of the renewed form with the expiration date of 06/30/2023 will be mandatory on 8/31/2020.  The ABN form and instructions may be found here.

AHCA/NCAL Members: Check Out the New Population Health Management Innovation Lab


AHCA/NCAL recently launched the first phase of its Population Health Management (PHM) Innovation Lab.  Phase I contains free “AHCA/NCAL Member Only” foundational resources designed to introduce AHCA/NCAL assisted living, nursing facility and intermediate care facility members and their staff to the wide array of PHM models available today and in the future.

Phase I PHM Innovation Lab resources are ideal for familiarizing owners, operators, administrators and LTC managers about the fundamentals of various PHM models and how these models can better serve LTC organizations, residents and families. Members can also access the PHM Innovation Lab resources at: PHMInnovationLab.com.

CMS continues to drive the healthcare system to one of value by shifting financial risk to providers through a range of fee-for-service (FFS) and managed care models. PHM is the application of interventions and strategies to improve the health outcomes and manage the costs of a targeted group.  PHM models vary based on the degree of risk, degree to which payments are tied to quality, reliance on data analytics and level of care coordination. Understanding these models is vital in today’s operating environment.

Historically, PHM models have been led by hospitals, health systems, physician groups and large insurance organizations. In recent years, LTC providers (including assisted living) and PAC providers have assumed leadership roles in developing and employing several PHM models. The new environment demands new models, and PHM helps LTC/PAC providers understand and integrate new strategies into SNF and AL buildings by integrating SNF/AL and primary care, enhancing care transitions, and using robust care management models.

PHM models have evolved to address targeted groups of individuals (SNF and AL residents in our case), to improve their health outcomes, and providers can use these models to drive better outcomes, strategies and interventions for handling the COVID-19 crisis. A PHM model, provider led Special Needs Plans (SNPs) can be an important solution in the current COVID-19 environment. With the deployment of on-site nurse practitioners providing primary care at the long term care bedside, costly and potentially dangerous hospital transfers can be avoided.

The PHM Innovation Lab Phase I contains six different subject area modules with corresponding educational components including webinars and briefs.  
  1. Population Health Management Fundamentals -- Describes the who, what, where, and how of Population Health Management (PHM). It also introduces various PHM models including their specific characteristics, benefits, and implications.  
  2. Accountable Care Organizations -- Provides an overview of the structure, financial model, and regulatory requirements of different ACOs. Types of ACOs covered include Medicare Shared Savings Programs and Next Generation ACOs.  
  3. Bundled Payments -- Provides an overview of the basics of bundled payments (episode-based payments) including what are bundled payments, how they work, and their implications for LTC and PAC providers.  
  4. Emerging Models: Direct Contracting -- Provides a detailed overview of Direct Contracting including types of participants, payment, beneficiary alignment, quality incentives, and a model timeline.  
  5. Managed Care -- Provides an overview of Medicare Advantage/ Provider-led Special Needs Plans (SNPs) and explains how SNPs work, and discusses the implications for LTC and PAC providers.  
  6. Provider Networks --Provides an overview of the why, what, and how of provider-owned integrated care networks and explains the benefits of provider networks.  
Members will need to login with their AHCA/NCAL usernames and passwords to access PHM Innovation Lab materials. For assistance obtaining AHCA/NCAL usernames and passwords, members should e-mail educate@ahca.org with their name and facility contact information.  

AHCA/NCAL’s Online Training Delivers the Real-World Tools Staff Members Need to Improve Functional Outcomes


AHCA/NCAL’s online training titled Functional Outcomes Improvement is 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.  


Monday, June 29, 2020

AHCA and CMS Recommend Two Infections Preventionists for SNFs


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

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. 
 
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.  

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.  

Friday, June 26, 2020

Claims Processing Guidance for 3-Day Stay and Spell-of-Illness Waivers

On June 26, the Centers for Medicare and Medicaid Services (CMS) updated SNF billing guidance related to Medicare beneficiaries receiving care when a SNF utilizes the COVID-19 public health emergency (PHE) 3-day stay and spell-of-illness waivers. The new guidance was posted in a revised MLN Matters article SE20011 under the heading “Skilled Nursing Facility (SNF) Benefit Period Waiver - Provider Information” (pages 9-13).

This section includes a summary of the waivers, examples of how beneficiaries could qualify for the qualifying hospital stay (QHS) 3-day stay waiver as well as the spell-of-illness benefit period waiver. Most importantly, CMS included detailed guidance for documentation, completing MDS assessments, and entering claims data needed in order to permit processing of claims using the waivers. CMS notes that the MACs will be required to manually process waiver claims but must “make every effort to ensure timely payment” within the 14 day payment floor. Finally, CMS provided guidance related to handling claims previously submitted that need to be addressed to bypass existing edits.

AHCA/NCAL highly recommends that providers review the guidance and share with clinical and billing staff. CMS is expected to post frequently asked questions (FAQs) associated with is updated billing guidance soon. AHCA/NCAL will notify members when the FAQs are posted.

CMS Memo Confirms PBJ Submission Deadline and Provides Five-Star Updates

On June 25, CMS released a QSO memo updating changes to the staffing and quality domains of Five-Star due to COVID-19. The updates include: 
  • Lifting the Payroll-Based Journal (PBJ) staffing data waiver. Nursing homes must submit calendar year Quarter 2 (April – June) 2020 PBJ data by August 14, 2020. This data will be used in Five-Star ratings updated in October 2020. 
  • Holding constant Five-Star Staffing ratings and measures from now through October 2020. Because submission of calendar year Quarter 1 (January – March) 2020 PBJ data remains optional, the staffing star ratings and measure will not be updated on the next Nursing Home Compare update on July 29, 2020. 
  • Updating Five-Star Quality ratings and measures on July 29, 2020. The quality measures will not reflect any assessments after December 31, 2019. There are several measures, mostly claims-based measures, that will be updated on Nursing Home Compare on July 29, 2020. Other measures that currently reflect data through December 31, 2019 will be held constant. 
Staffing Measures and Ratings Update

With this memo, CMS immediately ends the blanket emergency waiver of 42 CFR 483.70(q), which requires nursing home providers to submit staffing data through the Payroll-Based Journal (PBJ) system. This is a portion of the broader COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers, which largely remains in place. 

With the ending of the PBJ data submission waiver, facilities must submit the requisite staffing data for calendar Quarter 2 (April – June) 2020 through the PBJ system by August 14, 2020. 

Submission of calendar Quarter 1 (January – March) 2020 data was optional under the blanket waiver and remains so. CMS reports approximately 60 percent of facilities still submitted this data. While this data will not be used to calculate staffing measures or staffing ratings, it will be posted on CMS’s public use files available on data.cms.gov

Five-Star Staffing Star ratings currently on Nursing Home Compare are based on Quarter 4 (October – December) 2019 data. Ratings will continue to be based on this data till October 2020, when Quarter 2 (April – June) 2020 data is used. Quarter 1 (January – March) 2020 data will never be used to determine ratings. 

For facilities that currently have their Staffing Star ratings downgraded to one-star because of either missing the Quarter 4 – 2019 submission deadline or reporting four or more days with no RN hours, their staffing ratings and measures will temporarily be suppressed from July 29, 2020 through October 2020. This is because they will not have an opportunity to correct or improve their staffing ratings due to the PBJ data submission waiver.

Quality Measures and Ratings Update

Similar to the staffing data waiver, CMS previously waived requirements at 42 CFR 483.20 related to the timelines for completing and submitting resident assessment (minimum data set [MDS]) information. CMS believes data from assessments after January 1, 2020 cannot be used to calculate quality measures, but assessments prior to January 1, 2020 can be used.

On the next Nursing Home Compare update, which is scheduled for July 29, 2020, Five-Star quality ratings and measures will be updated using any underlying data that is available up to December 31, 2019. 

This is mostly applicable to claims-based measures, such as short-stay rehospitalization, which currently on Nursing Home Compare are through September 30, 2019. Other measures, such as the MDS-based pressure ulcer measure, already reflect assessments through December 31, 2019 and thus the rate will not change with the next Nursing Home Compare update. For a full list of measures and their current collection period, go to the “About the Data” page on Nursing Home Compare.

Health Inspections and Survey Ratings Update 

The Five-Star Survey rating domain remains frozen. CMS froze the survey domain to prioritize infection control surveys over standard, fire, and safety inspections. CMS is monitoring inspections and will restart survey ratings as soon as possible. When they are resumed will be communicated in a future memo.


Wednesday, June 24, 2020

Not Sure Where to Start with the HHS Medicaid Portal? Start Here!

AHCA/NCAL has drafted a tips sheet and step-by-step guide for providers on how to successfully navigate the new Provider Relief Fund Payment Portal for non-SNF Medicaid Providers. The application is due July 20, and unlike previous tranches, is not a first-come, first-serve process.

Therefore, providers have plenty of time to review and ensure that all data is gathered and accurate before submission. It is important to note that there is no-redo on your application submission. Once you submit data into the portal it is final – there are no appeals rights, modifications or resubmissions.

Our tips sheet will help you ensure that you fully vet your data with the FAQs, application instructions, excel workbook and related PDF application before starting the actual portal data entry and submitting your application.

As a reminder, HHS will be hosting a Medicaid Allocation Application online tutorial on Thursday, June 25, 2020 at 2 PM ET.

In addition, please ensure that you call the CARES Act Fund Hotline at (866) 569-3522 (for TTY dial 711) with specific questions or review HHS’s Frequently Asked Questions

Assisted Living Provider Survey Shows Communities Low on PPE

Katherine Preede

NCAL recently conducted a survey of assisted living communities on the availability of personal protective equipment (PPE). The survey found that more than half of assisted living communities have less than a two-week supply of vital PPE supplies and that more than 70 percent of communities have asked for help from state and local health agencies and yet were not able to procure the supplies. 

The survey also highlighted that many communities are reusing PPE in accordance with CDC strategies to optimize supplies and many facilities are still having to use homemade or improvised PPE (e.g., handsewn face masks).

As a reminder to all those communities that still need PPE, AHCA/NCAL has compiled a list of vendors that have successfully delivered PPE to members during the pandemic. Identifying reliable PPE suppliers during the COVID-19 pandemic has been challenging for providers. AHCA/NCAL has vetted countless vendors and concluded that the best indicator of potential suppliers is members’ experiences ordering and receiving supplies in this uncertain time. 

The survey also showed that COVID-19 testing continues to be a significant point of concern for LTC providers. AHCA/NCAL has resources around testing that members can utilize. Please also be aware of COVID scams as you are working to procure materials for your community.  

Tuesday, June 23, 2020

Learn New Workforce Recruitment and Retention Strategies in Just 45 Minutes


AHCA/NCAL offers an instructional webinar titled “Pioneering Solutions to the Workforce Crisis.”  This 45-minute webinar developed in collaboration with PHI delivers practical action steps and strategies assisted living and nursing facilities of all shapes and sizes can take to improve their employee and retention efforts. The webinar also covers ways to improve the hiring process and explains supportive supervision and coaching methods that positively impact employee retention.  

The webinar’s learning objectives include:
  1. Explain the key factors contributing to the workforce shortage
  2. Identify at least 3 strategies to improve employee recruitment
  3. Identify at least 3 strategies to improve employee retention
  4. Explain the impact of supportive supervision on retention
This webinar is part one to a more extensive on-line training for middle managers that will be released in the coming months. While no CEUs are offered for this webinar, participants can receive a certificate of completion. The cost of the course is $25 for AHCA/NCAL members and $60 for non-members.

The instructor is Sue Misiorski who served as Vice President of Workforce Innovations for PHI and currently serves as the New England Regional Director of Operations for SageLife. Starting as a CNA, she later held positions as a DON and VP of Nursing in multi-site skilled nursing homes in New England and has supported the construction of several assisted living and nursing facilities.

Follow this link to read more about this educational webinar and to register for the course.

To access ahcancalED and the Pioneering Solutions webinar, members will need to login with their AHCA/NCAL usernames and passwords. For assistance obtaining AHCA/NCAL usernames and passwords, individuals should e-mail educate@ahca.org with their name and facility contact information


New Interactive Online High Intensity Rehab Course Released for Physical and Occupational Therapists and Assistants


In collaboration with the University of Colorado (CU), AHCA/NCAL is launching a new online educational program titled High Intensity Physical Rehabilitation in Medically Complex Populations. This program is offered through ahcancalED and is designed for physical therapy and occupational therapy rehabilitation professionals (PT, PTA, OT, OTA).

The course presents an evidence-based approach for the implementation of a high intensity progressive rehabilitation model as part of an evolution from current lower intensity post-acute treatment approaches to address myriad patient needs. Rehabilitation professionals will have access to an interactive multimedia learning experience including responsive, self-paced presentation of foundational concepts, simulated case scenarios, and a moderated discussion environment for learning with fellow clinicians - all informed by the latest learning science and innovative technology.

The goal of the course is to teach rehabilitation professionals better methods of addressing functional decline due to underlying medical complexity and deconditioning from hospitalizations or illness. By the end of this course, rehab professionals will learn how to:
  1. Screen all patients for safe participation in high intensity rehabilitation
  2. Establish an appropriate high intensity plan of care for eligible patients
  3. Execute effective and engaging rehabilitation sessions informed by high intensity rehabilitation strategies
  4. Perform ongoing monitoring of patient response to activity and adapt high intensity plans of care throughout the length of stay
  5. Communicate and document completely and efficiently to facilitate continuity of care
  6. Identify current gaps in care for older adults that high intensity rehabilitation can address and advocate for its use in the skilled nursing setting
This self-paced course contains nine learning modules. Each module has an interactive lesson. Some modules have quizzes, some have Slack channel discussions, and some have case simulations to test the mastery of the subject matter. The course concludes with the Post-Assessment/Final Exam and survey.  All modules must be completed to take the Post-Assessment/Final Exam. 

CU recommends that the course be taken over an eight-week period to allow rehab professionals time to implement and practice the concepts as they are learned. Documentation will be provided by AHCA/NCAL to rehab professionals who successfully complete the course, so that they can apply to their respective state licensing boards for continuing education credits.

The course fee is $495 for an employee or contracted employee registering as affiliated with an AHCA member facility and $595 for all other non-member registrants. Individuals will register and pay for the course through the ahcancalED platform at this web site: ahcancal.org/restoreregistration. Then, within 48 hours, registrants will receive further instructions on how to go to the CU platform and enroll in the course and begin their coursework. 

Individuals will need to login with their AHCA/NCAL usernames and passwords to register for this course. For assistance obtaining AHCA/NCAL usernames and passwords, individuals should e-mail educate@ahca.org with their name and facility contact information. Questions about the program should also be directed to educate@ahca.org.




Monday, June 22, 2020

HHS Updates Provider Relief Fund FAQs

On June 22, made several updates to the Provider Relief Fund FAQs.
 
HHS added detail on calculating lost revenue and revenue (page 7) 

“You may use any reasonable method of estimating the revenue during March and April 2020 compared to the same period had COVID-19 not appeared. For example, if you have a budget prepared without taking into account the impact of COVID-19, the estimated lost revenue could be the difference between your budgeted revenue and actual revenue. It would also be reasonable be the difference between your budgeted revenue and actual revenue. It would also be reasonable to compare the revenues to the same period last year.”  

On page 38, HHS also notes that patient out-of-pocket costs should be counted as revenue. Later on page 39, HHS indicates that revenue lost under Medicaid value-based purchasing programs may be counted as lost revenue.  

Duration of Terms and Conditions (page 9) 

“Some Terms and Conditions relate to the provider’s use of the funds, and thus they apply until the provider has exhausted these funds. Other Terms and Conditions apply to a longer time period, for example, regarding maintaining all records pertaining to expenditures under the Provider Relief Fund payment for three years from the date of the final expenditure”. 

Change in Ownership Additional Detail (page 9)

HHS elaborates upon scenarios in which sellers may not transfer funds.  

Medicaid Allocations (page 38) 

HHS notes that even a small General Distribution payment makes a provider ineligible for the Medicaid Allocation. The Department also added detail on who may apply noting that if a provider did not bill Medicaid/CHIP during the eligibility window, providers may apply  for Medicaid allocation funding as long as they provided diagnoses, testing, or care for individuals with possible or actual cases of COVID-19 after January 31, 2020 and can produce evidence of such care.  

Additionally, HHS limits on page 39 which providers who enrolled as Medicaid/CHIP providers in 2020 may apply. Also, on page 39, the Department notes that providers who bill under Medicaid Managed Care may apply.  

Tax Information 

On pages 38 and 41, HHS clarifies needed tax documentation information.  

 
Additional Information on This Week’s Webinars 

On Tuesday, June 23 and Thursday, June 25, HHS will be offering webinars on the Medicaid Allocation application process. To register for one of the webinars, click here
 
 
 

Thursday, June 18, 2020

HHS Offers Medicaid Allocation Application Tutorials

The HHS Provider Relief Fund Medicaid Application Process while a positive step also has come with a number of questions. Unlike Tranches 1-3, the Medicaid Allocation requires an application requiring an array of data. Today, HHS announced two Medicaid Allocation Application online tutorials. The date options are below and please note: you must pre-register.  
Meanwhile, AHCA/NCAL has submitted a list of questions about the application process, along with other provider groups and are awaiting responses from HHS. 

Medicaid Allocation Applications on due on July 20. View AHCA/NCAL’s Medicaid Allocation FAQs in our recent blog post

AHCA/NCAL Webinar on Economic Impact Payments for Social Security and SSI Beneficiaries with Representative Payees

AHCA/NCAL recently put together a webinar recording on economic impact payments (EIPs) from the Internal Revenue Service (IRS) and important facts for skilled nursing facilities, ICFs/IID, and assisted living communities to know on the use of them. IRS began issuing electronic EIPs on or about April 15 to people who received a tax refund electronically.  

The webinar covers what EIPs are and what steps providers should take to protect beneficiaries receiving this benefit. EIP funds belong to the resident and they make decisions about fund use or may request assistance and guidance (such supports are acceptable). The recording also covers whether a resident can give their EIP funds to a family member and what to do if EIP funds are being misused. Finally, a variety of resources from the Social Security Administration to the National Center on Elder Law and Rights are available at the end of the webinar to find further information that will be of assistance.  

This webinar is available on-demand and for free to member providers and the general public. Viewers must create an account with or log in to ahcancalED. 

Also see our blog post, which offers guidance on this topic. 

If you have any questions around EIPs, please email COVID19@ahca.org.  

 

Wednesday, June 17, 2020

Outlook for Three-Day Hospital Waiver

In the past months, CMS has issued an array of national, “blanket” waivers to reduce administrative burden, improve access to care, and expedite provider payment in both the Medicare and Medicaid programs. Important Medicare SNF waivers include waive of the 3-Day Stay Rule and Spell of Illness while an important Medicaid waiver is the elimination recertification requirements. These waivers, included under a national, blanket waiver called a Section 1135 waiver, remain in place while a Public Health Emergency (PHE) is in force.

Under the President’s March declaration of a PHE under Section 319 of the Public Health Service Act, the Secretary of the Department of Health and Human Services (HHS) has the authority to declare a PHE exists in 90-day increments. Effective April 26, HHS Secretary Azar announced a PHE 90 day extension through July 26. In late July, Secretary Azar has two options:
  1. Allow the PHE and the Section 1135 to expire; or 
  2. Allow the PHE to expire but extend the Section 1135.

The Secretary has the authority to extend the Section 1135 in 60-day increments. As an example, Secretary Azar could allow the PHE to expire on July 26 but extend the Section 1135 waiver until September 26 and then, again, until November 26.


Outlook for Other Important Resources

In addition to the waivers, important resources are increased federal Medicaid funding for states with a 6.2 percentage point increase and the CARES Act Provider Relief Fund. Increased federal Medicaid funding to the states is tied to the PHE. The increased federal dollars are available for qualifying expenditures that were incurred on or after January 1, 2020 and through the end of the quarter in which the public health emergency including any extensions, ends. Following the example above, if the Secretary allows the PHE to end on July 26, the increased federal matching percentage would end on September 30. 

The CARES Act Provider Relief Fund is not tied to any date in the CARES Act statutory language nor the PHE. The Fund is entirely at the discretion of the Secretary.


Tuesday, June 16, 2020

Register Today for AHCA/NCAL’s Infection Preventionist Training


AHCA/NCAL’s expanded version of its popular Infection Preventionist Specialized Training (IPCO Version 2) online training now includes COVID-19 bonus content.

IPCO Version 2 is designed to train nursing facility 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 facility operations. The training is also highly recommended for assisted living communities because they care for a similar population with similar infection risks.

The registration fee is $450 for AHCA/NCAL members and $650 for non-members. Members will need to login with their AHCA/NCAL usernames and passwords to register for IPCO Version 2. For help obtaining AHCA/NCAL usernames and passwords, members should e-mail educate@ahca.org with their name and facility contact information. 

Whether You Need to Know Some, a Lot, or Just Need Updates, AHCA’s Online SNF ICD-10 Coding Trainings Have You Covered


AHCA has partnered 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 PDPMFull 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 PDPMFull 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/NCAL Launches New Population Health Management Innovation Lab for Members


AHCA/NCAL has launched the first phase of its Population Health Management (PHM) Innovation Lab.  Phase I contains free “AHCA/NCAL Member Only” foundational resources designed to introduce AHCA/NCAL assisted living, nursing facility and intermediate care facility members and their staff to the wide array of PHM models available today and in the future.  

Phase I PHM Innovation Lab resources are ideal for familiarizing owners, operators, administrators and LTC managers about the fundamentals of various PHM models and how these models can better serve LTC organizations, residents and families. Members can also access the PHM Innovation Lab resources at: PHMInnovationLab.com.  

CMS continues to drive the healthcare system to one of value by shifting financial risk to providers through a range of fee-for-service (FFS) and managed care models. PHM is the application of interventions and strategies to improve the health outcomes and manage the costs of a targeted group.  PHM models vary based on the degree of risk, degree to which payments are tied to quality, reliance on data analytics and level of care coordination. Understanding these models is vital in today’s operating environment.

Historically, PHM models have been led by hospitals, health systems, physician groups and large insurance organizations. In recent years, LTC providers (including assisted living) and PAC providers have assumed leadership roles in developing and employing several PHM models. The new environment demands new models, and PHM helps LTC/PAC providers understand and integrate new strategies into SNF and AL buildings by integrating SNF/AL and primary care, enhancing care transitions, and using robust care management models.

PHM models have evolved to address targeted groups of individuals (SNF and AL residents in our case), to improve their health outcomes, and providers can use these models to drive better outcomes, strategies and interventions for handling the COVID-19 crisis. A PHM model, provider led Special Needs Plans (SNPs) can be an important solution in the current COVID-19 environment. With the deployment of on-site nurse practitioners providing primary care at the long term care bedside, costly and potentially dangerous hospital transfers can be avoided.  

The PHM Innovation Lab Phase I contains six different subject area modules with corresponding educational components including webinars and briefs.  
  1. Population Health Management Fundamentals -- Describes the who, what, where, and how of Population Health Management (PHM). It also introduces various PHM models including their specific characteristics, benefits, and implications.  
  2. Accountable Care Organizations -- Provides an overview of the structure, financial model, and regulatory requirements of different ACOs. Types of ACOs covered include Medicare Shared Savings Programs and Next Generation ACOs. 
  3. Bundled Payments -- Provides an overview of the basics of bundled payments (episode-based payments) including what are bundled payments, how they work, and their implications for LTC and PAC providers.  
  4. Emerging Models: Direct Contracting -- Provides a detailed overview of Direct Contracting including types of participants, payment, beneficiary alignment, quality incentives, and a model timeline.  
  5. Managed Care -- Provides an overview of Medicare Advantage/ Provider-led Special Needs Plans (SNPs) and explains how SNPs work, and discusses the implications for LTC and PAC providers.  
  6. Provider Networks --Provides an overview of the why, what, and how of provider-owned integrated care networks and explains the benefits of provider networks.  
Members will need to login with their AHCA/NCAL usernames and passwords to access PHM Innovation Lab materials. For assistance obtaining AHCA/NCAL usernames and passwords, members should e-mail educate@ahca.org with their name and facility contact information.  


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 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.

Monday, June 15, 2020

NHSN Reporting Citations and CMPs Rescinded

Some members have begun to receive notices in CASPER rescinding the F884 citation and Civil Monetary Penalty (CMP) they were given for allegedly not reporting complete information to NHSN about COVID-19 in the standardized format and frequency specified by CMS and CDC. The letter indicates that due to its internal reviews of the NSHN data submissions, CMS is deleting the F884 deficiency and rescinding the CMP imposed for the June 1-June 7, 2020 reporting week.

These rescind letters may be sent through mail and/or through CASPER as with the F884 citations and enforcement letters and may be accompanied by an email notification to facility staff that have an MDS account in CASPER. If you believe you successfully submitted NHSN data and received a citation and CMP in error, please check your CASPER folder for one of these rescind letters.

AHCA will share any further information we receive.

IIDR Sample Request on NHSN Reporting Citation

For facilities that have not received a rescind letter from CMS, but still believe the F884 citation was issued in error or inappropriately, at this time you must still submit an independent information dispute resolution (IIDR) request, as indicated in the enforcement letter. You must submit that request within 10 calendar days of receipt of the enforcement letter, which is being provided through CASPER. Be sure to include supporting documentation of your data submissions and/or documentation of your efforts to resolve any technical issues with NHSN registration or data submissions in advance of the reporting deadlines.

To assist in this process, we are sharing this sample IIDR request. This is only a sample and you must tailor it to your situation. Please review the instructions in the document before completing it and consult with your counsel in this process as appropriate.

AHCA will continue to advocate that CMS improve this process and make it fairer and more transparent.

Friday, June 12, 2020

Webinar: Providers Share Their Experiences with COVID-19 Telehealth Waivers

AHCA/NCAL has posted a 45-minute webinar on ahcancalED in which four members, from independent owners to large multistate for-profit and nonprofit organizations, share their experiences in implementing the COVID-19 telehealth waivers, and how the waivers have helped improve care during the public health emergency (PHE). The webinar is free to AHCA/NCAL members and is viewable on-demand.

Since March 1, 2020, the Centers of Medicare and Medicaid Services (CMS) has removed geographic telehealth limits, limits on the type of services and frequencies of physician telehealth visits, limits on telehealth services that non-physician practitioners such as nurse practitioners can furnish, and removed the prohibition on furnishing physician and occupational therapy and speech-language pathology services via telehealth. Additionally, relaxation of certain privacy regulations by the Department of Health and Human Services (HHS) has permitted an explosion in the use of lower-cost, audio/visual technology including smartphones, tablets, and software such as facetime and skype in the delivery of telehealth services.

The presenters share their thoughts on which waiver details they would like for AHCA/NCAL to advocate to CMS, HHS, and Congress to make permanent.

Update on NHSN Reporting and Related Citations & Fines

AHCA received communication from the Centers for Medicare and Medicaid Services (CMS) late last night (June 11) regarding NHSN reporting. CMS is researching the issues resulting in providers being marked as noncompliant. 

CMS reports that there are a few common issues they have discovered so far, including:
  • facilities not entering the right CCN 
  • facilities not selecting the right facility type
  • facilities entering data after the Sunday deadline, but for the reporting week, and
  • facilities entering data during the week but for previous week’s data 
CMS is seeking the center’s help to get these corrected and straightened out. The Centers for Disease Control and Prevention (CDC) National Healthcare Safety Network (NHSN) is looking into some actions that they can take to make it easier for these issues to be identified on the facility side of the platform.

Steps that your center can take now to ensure your data is being uploaded correctly include: 
  • Check to make sure that your CCN number is correct 
  • Check to ensure that your facility type is correct 
  • Ensure that you are submitting data prior to 11:59pm each Sunday 
  • Data submitted should be new data since previous submission. Do not enter cumulative data in NHSN.
  • Enter zero (0) if the answer is zero for questions requiring counts. Blank data elements equal missing data. All pathways must be completed. 

CMS has stated that they intend to be fair on reviewing IDRs for citations and CMPs issued as part of this regulation as long as providers can show that they did submit the data or have been trying to register or submit the data but had delays in resolving challenges because of CDC’s help line being overwhelmed with requests.

According to the CDC/NHSN, some centers are being identified as “duplicates” because they have registered more than once with the same CCN. Duplicate facilities can lead to problematic scenarios, including: 
  • User reporting data for both NHSN facility accounts 
  • User intermittently reporting into both NHSN facility accounts during the same time period 
  • User reports into one account for a period of time, then switches to the other account for a period of time 
Unfortunately, the CDC/NHSN system cannot delete either account due to not knowing which account is the accurate account. CDC/NHSN has provided the following guidance for centers to correct this issue:

Correct the Facility CCN
If you are unsure of your facility’s CCN, please refer to the look-up tool and follow the instructions below:
  1. Using the left navigation pane, select "Basic Search" under "Tool".
  2. On the next page, enter your facility information and click the “Search” button.
  3. Select your facility on the basic search results report screen to view results and the CCN.
  4. Compare your CCN generated by the look-up tool to the CCN recorded in NHSN. If these differ, please enter the correct CCN for your facility in NHSN. To change the CCN listed in NHSN, please refer to this guidance document.  
Remove Multiple Enrollments 
A facility should not enroll in NHSN more than once and create more than one NHSN OrgID. Each NHSN Org ID should only have one CCN affiliated with that Org ID. Facilities enrolled more than once and share the same CCN will not have accurate data recorded and submitted to CMS.

Please follow these steps to withdraw any duplicate facilities:
  1. Choose one NHSN facility OrgID to submit data and ensure the CCN is correct.
  2. Merged from any duplicate facilities into the one designated facility from step #1.
  3. Withdraw duplicate facilities from NHSN by doing the following:
    1. Log into the duplicate enrolled facility in NHSN.
    2. On the left navigation pane, select facility->facility info.
    3. Scroll down to the component itemization and deselect the component that is a duplicate.
    4. Accept the alert indicating that you’ve deselected the facility.
    5. Select update to reflect changes.
  4. Add users to the one NHSN facility chosen in step #1, if needed.
Add a NHSN User 
  1. Log into SAMS and selecting NHSN reporting. 
  2. Go to the left navigation pane and click on Users>ADD.
  3. Complete the required fields marked with an asterisk (*) and click SAVE at the bottom of the page.
  4. Assign user rights and click on SAVE at the bottom of page.
  5. Ensure that you have made all users an “Active User.”
If a newly added user does not have SAMS access, they should receive an email confirmation following this process. The email will also ask the new user to click on the corresponding link to agree to the NHSN Rules of Behavior. Once they agree to the Rules of Behavior, NHSN will automatically submit an invite to the user for SAMS authentication.

Correct Erroneous Data
Centers can correct errors in data by logging into the NHSN system and navigate to the calendar view.
  1. Click on the data that data needs correcting.
  2. Click on the pathway that needs correcting
  3. Correct the erroneous data
  4. Click SAVE
NHSN Help Desk contact info: nhsn@cdc.gov

SAMS Help Desk contact info: SAMSHelp@cdc.gov or (877) 681-2901

CMS Help Desk contact info: NH_COVID_Data@cms.hhs.gov

Thursday, June 11, 2020

CMS Issuing F884 Citation and CMPs for Failure to Report NHSN COVID-19 Data

This week, CMS began issuing 2567s with F level citations for F884 with a $1,000 per instance civil monetary penalty (CMP). These are being issued to all SNFs identified by CMS from data transmitted by CDC as not having submitted data or submitting incomplete or otherwise erroneous data for the week of June 1 to June 7. The notifications of deficiency and CMP are being sent via the CASPER/QIES system (not the traditional method for notifying a facility with a deficiency). Thus, facilities must log in to CASPER to see if they have a citation or not. Your MDS coordinator will know how to access this system if you need help.

Background:

The interim final rule requires SNFs to submit data to CDC through the NHSN portal starting June 1; any SNF that does not submit the required data will be issued a citation at F884 and a $1,000 per instance CMP. If the facility in subsequent weeks fails to submit data, the CMP escalates. 

CMS is generating an automatic 2567 with F884 citation for facilities that have not submitted data starting with the week of June 1 to June 7. CMS will continue to review weekly if data was submitted and issue citations and CMP enforcement for facilities that it determines are not compliant. 
  • All facilities are cited at F884 at an F level. 
  • At this time, language in the 2567 is the same for all providers and does not specify what data was not submitted: 
“This REQUIREMENT is not met as evidenced by: Based on record review, the facility failed to report complete information about COVID-19 to the Centers for Disease Control and Prevention’s (CDC) National Healthcare Safety Network (NHSN) during a seven-day period that reporting was required by regulation. The CDC submitted data from the NHSN to the Centers for Medicare and Medicaid Services (CMS). Based on review of that data, CMS determined that between 06/01/2020 and 06/07/2020, the facility did not report complete information to NHSN about COVID-19 in the standardized format and frequency as specified by CMS and the CDC. This failure to report has the potential to cause more than minimal harm to all residents residing in the facility.”

CMS has said a facility can question the cited deficiency through the IIDR process by following the steps outlined in the notification letter and will give consideration for facilities that have evidence showing they submitted the data or have been trying to register and submit data but ran into technical issues.

We will continue to advocate that CMS make changes to have a more accurate and fairer process, and give providers due consideration when the errors are due to CDC/NHSN or CMS. 

In the meantime: 
  1. You should check CASPER to see if you have a citation. 
  2. If you have a citation that you believe is in error, then you should assemble the information needed to submit an IIDR. We recommend putting together at least the following: 
    • A summary table of dates they started the registration process and all dates of communications with CDC/NHSN 
    • Screen shots if you have documented your data submission (and begin taking screen shots or other verification evidence of each submission) 
    • Copies of emails sent and received from CDC/NHSN 
    • Any other documentation of efforts you made to register and submit data such as communications with the QIO or state.
Please email COVID19@ahca.org for additional questions, or visit ahcancal.org/coronavirus for more information.

CMS Releases New ICFs/IID FAQs

On June 10, CMS released new FAQs for intermediate care facilities for individuals with intellectual or developmental disabilities (ICFs/IID) related to COVID-19. 

Questions and answers covered include: 

  • How should an ICF handle the discharge summary when a client is admitted on a temporary emergency basis from the community or another ICF? 
  • How should an ICF handle the development of a Comprehensive Functional Assessment and an Individual Program Plan when a client is admitted on a temporary emergency basis from the community or another ICF? 
  • During the public health emergency are ICFs still required to have and use a specially constituted committee or committees? 
  • When a client has tested positive for COVID-19 and the ICF/IID implements quarantine procedures, client rights are immediately abridged and severe behaviors are likely to occur. What is the guidance from CMS on balancing the CDC expectations with the rights of the individual? 
  • Are ICFs required to participate in the COVID-19 CDC National Healthcare Safety Network reporting requirements? 

The ICFs/IID FAQs are listed on pages 13-15 here.

Please email COVID19@ahca.org for additional questions, or visit ahcancal.org/coronavirus for more information.

Applying COVID-19 Infection Prevention and Control Strategies in Nursing Homes

On Tuesday, June 16, the Centers for Disease Control and Prevention (CDC) Clinical Outreach and Communication Activity (COCA) will be hosting a webinar on applying COVID-19 infection prevention and control strategies in nursing homes. CDC presenters, Dr. Nimalie Stone and Dr. Kara Jacobs-Slifka, will use case-based scenarios to discuss how to apply infection prevention and control guidance for nursing homes and other long term care facilities that are preparing for and responding to COVID-19. 

Applying COVID-19 Infection Prevention and Control Strategies in Nursing Homes  
Tuesday, June 16 
2:00 p.m. - 3:00 p.m. (ET) 
Join via Zoom
Join by phone: US: +1 669 254 5252 or +1 646 828 7666 
Spaces are limited for the live webinar.  

If you are unable to attend the live COCA Call, the recording will be available for viewing on the COCA Call webpage a few hours after the live event ends. The slide set will be available under "Call Materials" on the COCA Call webpage.

Please email COVID19@ahca.org for additional questions, or visit ahcancal.org/coronavirus for more information.

Therapy Coalition Submits Request to Extend Therapy Telehealth Waivers

On June 10, AHCA/NCAL and 13 other therapy advocacy organizations submitted a letter to HHS Secretary Azar, CMS Administrator Verma, and other key CMS officials requesting extension of COVID-19 therapy telehealth waivers as well as efforts to make these policies permanent in law. AHCA/NCAL worked closely with this coalition in the development of this letter, which also aligns with previously submitted AHCA/NCAL comments regarding the COVID-19 Interim Final Rule as well as in the FY 2021 SNF PPS Notice of Proposed Rule Making.  

Please email COVID19@ahca.org for additional questions, or visit ahcancal.org/coronavirus for more information.

Wednesday, June 10, 2020

Relief Fund Portal for Medicaid Providers Launches

On June 10, the U.S. Department of Health and Human Services (HHS) launched a web application portal for Medicaid providers other than SNF Medicaid providers. SNF Medicaid-only providers already should have received a Medicaid Allocation or will receive payments over the course of the week. The new Provider Relief Fund Payment Portal will initially be used for new submissions from Medicaid and Children’s Health Insurance Program (CHIP) providers seeking payments under the Provider Relief Fund including assisted living communities, ICFs/IID, and home and community-based providers.

HHS also as prepared instructions on how to complete the Medicaid Distribution and a downloadable PDF of the application. The latter should be used a worksheet in conjunction with the instructions before entering data into the web portal. Ensuring accuracy of web portal data entry is important because once an application is submitted, it may not be modified.

Of note, the new Provider Relief Fund Payment Portal also may be used by providers who did not receive payments under the previous General Distribution, including those providers who bill Medicaid and CHIP (e.g., pediatricians, long-term care and behavioral health providers.). For example, providers who engaged in a change in ownership and who also had Medicaid revenue during a specified period (see FAQ summary) may use the Payment Portal to request funds.

To view a summary of FAQs pertaining to the new Payment Portal as well as other June 10 FAQ updates highlights, read more from our blog post. Of note, HHS discusses use of funds for longer term expenses and lost revenue in its updated FAQs.

If you have questions about CARES Act Provider Relief Fund awards, please contact the Fund Hotline at (866) 569-3522; for TTY dial 711. Use of the Hotline is the most expeditious way address questions. HHS will not respond to provider-specific questions.

Please email COVID19@ahca.org for additional questions, or visit ahcancal.org/coronavirus for more information.

FAQs: Medicaid Provider Portal for AL & ID/DD

On June 10, the U.S. Department of Health and Human Services (HHS) updated its Provider Relief Fund FAQs. The update provides information on the new web application portal for Medicaid providers other than SNF Medicaid providers. SNF Medicaid-only providers already should have received a Medicaid Allocation or will receive payments over the course of the week. The new Provider Relief Fund Payment Portal will initially be used for new submissions from Medicaid and Children’s Health Insurance Program (CHIP) providers seeking payments under the Provider Relief Fund including assisted living communities (ALs), ICFs/IID, and home and community-based providers.

Ensuring accuracy of web portal data entry is critical because once an application is submitted, it may not be modified. To help ensure web portal submissions are complete and accurate, HHS has prepared instructions on how to complete the Medicaid Distribution and a downloadable PDF of the application. Questions on the instructions and worksheet should be directed to the CARES Act Fund Hotline at (866) 569-3522; for TTY dial 711. 

Medicaid 


What types of Medicaid providers may apply? 

Medicaid and CHIP providers experiencing lost revenues or increased expenses due to COVID-19 may apply. Examples of Medicaid/CHIP providers possibly eligible for this funding include pediatricians, obstetrician-gynecologists, dentists, opioid treatment and behavioral health providers, assisted living communities and other home and community-based services providers.
*Providers also must meet three requirements see “Other FAQ Updates,” below. 

If I accept Medicaid as a revenue source in addition to Medicare and other payers am I eligible? 

Providers who received General Distribution awards under Tranche 1, which was based on 2019 Medicare Fee-for-Service claims, or Tranche 2, which was based upon other revenue from 2018 Cost Reports, are not eligible for Medicaid Allocation payments. Providers who received a SNF or other Allocation outside of General Distribution are eligible for a Medicaid Allocation. HHS also goes into more detail on Medicaid Allocation eligibility on page 32 of the June 10 FAQs. 

What is the formula for Medicaid Allocation payments? 

The Medicaid Targeted Distribution methodology will be based upon 2% of (gross revenues * percent of gross revenues from patient care) for CY 2017, or 2018 or 2019, as selected by the applicant and with accompanying submitted tax documentation. Payments will be made to applicant providers who are on the filing Tax Identification Number (TIN) list submitted by states to HHS or whose applications underwent additional validation by HHS. Read the Medicaid Allocation press release.

Will other factors impact a Medicaid Allocation payment? 

In the Medicaid Allocation press release, HHS notes, “The payment to each provider will be at least 2 percent of reported gross revenue from patient care; the final amount each provider receives will be determined after the data is submitted, including information about the number of Medicaid patients providers serve.” While the portal has not yet been examined in detail, it appears that HHS will evaluate the Medicaid award amount based upon submitted financial information as well as the number of Medicaid beneficiaries supported in the CY of submitted data.

Do I need to attest to Terms and Conditions for the Medicaid Allocation? 

Yes – you must attest to Terms and Conditions.

I received only a SNF Allocation and attested to those Terms and Conditions. Are there differences between the SNF Allocation Terms and conditions and the Medicaid Terms and Conditions?

No. There are no differences between the SNF Allocation Terms and Conditions and the Medicaid Terms and Conditions.

Can I edit, re-access or resubmit my General Distribution submission that I previously submitted prior to June 3, 2002 in this new portal? 

No. The new Targeted Distribution portal will not process applications from providers who have received payment from the previous $50 billion Provider Relief Fund General Distribution. 

Am I able to edit or resubmit my Medicaid Targeted Distribution Provider Relief Fund Payment Portal application? 

You can only submit one application. You can edit the data on the application form, until the form is submitted. You cannot edit or resubmit the application form once it is submitted. You should not apply until you have available all of the information and documentation required by the application form. 

If I rejected my General Distribution payment, can I apply for a Medicaid Targeted Distribution payment? 

No, if you were eligible for the General Distribution payment and rejected the payment, you cannot be eligible for Medicaid Targeted Distribution payment. 

What if a Medicaid provider is not on the filing TIN list submitted by states to CMS? 

Payments will be made to applicant providers who are in the filing TIN curated list from CMS. If applicants are not on that list, HHS will establish an additional process to validate eligibility. 

A subsidiary of ours received payments from the $50 billion General Distribution, but another subsidiary of ours did not and is a Medicaid provider – can I apply for this Medicaid Targeted Distribution? 

As long as the Filing TIN or one of the Billing TINs was not eligible for the $50B General Distribution, but is a Medicaid provider and is on the State-provided list of eligible Medicaid and CHIP providers, then they are eligible to apply. Medicaid providers who are not on the State-provided list, their applications will undergo additional validation by HHS. 

When is the deadline to submit an application? 

The deadline to submit an application for the Medicaid Targeted Distribution is July 20, 2020. 

Will I receive funds right away? 

No. HHS will review submissions through the application portal and make determinations as quickly as possible. Providers should be prepared for additional information requests from HHS. 

Other FAQ Updates 


Who is eligible for the Medicaid Targeted Distribution? 

To be eligible to apply, the applicant must meet all of the following requirements: 
  1. Must not have received payment from the $50 billion General Distribution; and 
  2. Must have directly billed Medicaid for healthcare-related services during the period of January 1, 2018, to December 31, 2019, or (ii) own (on the application date) an included subsidiary that has billed Medicaid for healthcare-related services during the period of January 1, 2018, to December 31, 2019; and 
  3. Must have either (i) filed a federal income tax return for fiscal years 2017, 2018 or 2019 or (ii) be an entity exempt from the requirement to file a federal income tax return and have no beneficial owner that is required to file a federal income tax return. (e.g. a state-owned hospital or healthcare clinic); and 4. must have provided patient care after January 31, 2020; and 5. must not have permanently ceased providing patient care directly, or indirectly through included subsidiaries; and 6. if the applicant is an individual, have gross receipts or sales from providing patient care reported on Form 1040, Schedule C, Line 1, excluding income reported on a W-2 as a (statutory) employee. 
[AHCA Note: DHHS has indicated the provision above allows current owners who participated in a change in ownership (CHOW) and have not receive any funds under Tranches 1 and 2 due to the CHOW may use the Payment Portal as long as they meet all three requirements above. AHCA/NCAL will continue to work on a solution for Medicare-only CHOWs.] 


If a healthcare provider changed its fiscal year and filed a partial year cost report, will this impact its General Distribution payment? If so, how can a provider indicate the cost year report does not reflect an entire year? 

Additional General Distribution payments are determined based on the lesser of 2% of a provider’s 2018 (or most recent complete tax year) gross receipts or the sum of incurred losses for March and April. HHS is collecting the “gross receipt or sales” or “program service revenue” data to have an understanding of a provider’s usual operations; the revenue loss information to have an understanding of COVID impact; and, tax forms to verify the self- reported information. Cost reports made up one of several data elements that HHS used to determine payments. 

In order to accept a payment, must the provider have already incurred eligible expenses and losses higher than the Provider Relief Fund payment received? 

No. Providers do not need to be able to prove, at the time they accept a Provider Relief Fund payment, that prior and/or future lost revenues and increased expenses attributable to COVID-19 (excluding those covered by other sources of reimbursement) meet or exceed their Provider Relief Fund payment. Instead, HHS expects that providers will only use Provider Relief Fund payments for permissible purposes and if, at the conclusion of the pandemic, providers have leftover Provider Relief Fund money that they cannot expend on permissible expenses or losses, then they will return this money to HHS. HHS will provide directions in the future about how to return unused funds. HHS reserves the right to audit Provider Relief Fund recipients in the future and collect any Relief Fund amounts that were used inappropriately. 

Are Provider Relief funds accessible in whole or in part to bankruptcy creditors and other creditors in active litigation? 

Payments from the Provider Relief Fund shall not be subject to the claims of the provider’s creditors and providers are limited in their ability to transfer Provider Relief Fund payments to their creditors. A provider may utilize Provider Relief Fund payments to satisfy creditors’ claims, but only to the extent that such claims constitute eligible health care related expenses and lost revenues attributable to coronavirus and are made to prevent, prepare for, and respond to coronavirus, as set forth under the Terms and Conditions. 

The Terms and Conditions require recipients to attest that for all care for a presumptive or actual case of COVID-19 the recipient will not seek to collect from the patient out-of-pocket expenses in an amount greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network recipient. How should skilled nursing facilities comply with this requirement? 

For skilled nursing facility patients with insurance, an out-of-network skilled nursing provider delivering care to a presumptive or actual COVID-19 patient may not seek to collect from the patient out-of-pocket expenses, including deductibles, copayments, or balance billing, in an amount greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider. 

Change from “Net Revenue” to “Gross Receipts” 

Through-out the FAQs, DHHS has replaced net revenue with gross receipts.


Please email COVID19@ahca.org for additional questions, or visit ahcancal.org/coronavirus for more information.