HQIN: COVID-19 Focused Survey Readiness Book & Office Hours Call

As your CMS-funded Quality Innovation Network – Quality Improvement Organization (QIN-QIO), the Health Quality Innovation Network (HQIN) offers resources to help you deliver the best possible care to your residents. To prepare your facility for the COVID-19 Focused Survey, we have created a “COVID-19 Focused Survey Readiness Book,” a comprehensive checklist intended to help facilitate a smoother survey. This three-page resource outlines the required entrance documents as well as additional resources that may be requested during the survey. Having these documents in-hand before the survey is initiated will ensure you are well prepared for the visit.

HQIN will be hosting a COVID-19 Focus Survey Preparedness “Office Hours” call on Wednesday, April 15 from 1:00-2:00 p.m. CT. Click here to register.

We encourage you to submit questions in advance to aspangler@hqi.solutions with “Office Hours” in the subject line. There will also be a live Q&A.

 

Important Information Regarding State Waiver Implementation for the Certified Medication Technician Training Program

SLCR has issued guidance for the implementation of state waivers related to the certified medication technician training program. Please read through this important guidance. Questions regarding these waivers should be directed to CNARegistry@health.mo.gov.

Please see the documents below for details.
CMT Waiver Implementation 4-9-20
Certified Medication Technician Training Program 4-9-20

Important Information Regarding State Waiver Implementation for the Level I Medication Aide Training Program

SLCR has issued guidance for the implementation of state waivers related to the Level I Medication Aide training program. Please read through this important guidance. Questions regarding these waivers should be directed to CNARegistry@health.mo.gov.

Please see the documents below for details.
LIMA Waiver Implementation 4-9-20
Level I Medication Aide 4-9-20

CMS Call on COVID-19 with Nursing Homes

Please join the Centers for Medicare and Medicaid Services (CMS) for a call on COVID-19 with Nursing Homes today, Wednesday, April 8th at 3:30 PM CST. CMS leadership will provide updates on the agency’s latest guidance and we will be joined by leaders in the field interested in sharing best practices with their peers. The call will be recorded if you are unable to join us.

Dial-in details below. Conference lines are limited, so we highly encourage you to join via audio webcast, either on your computer or smartphone web browser. You are welcome to share this invitation with your colleagues and membership.

Date: Wednesday, April 8th from 3:30 – 4:00 PM CST
Attendee Dial-In: 833-614-0820
Conference ID: 6798274
Web Link: https://protect2.fireeye.com/url?k=fe1249b7-a24740a4-fe127888-0cc47adb5650-02e519beae86a324&u=https://engage.vevent.com/rt/cms2/index.jsp?seid=1822

Missouri Interim Guidance on Crisis Capacity Strategies for PPE

The Missouri Department of Health and Senior Services (DHSS) has created a document offering guidance on strategies for optimizing the use of PPE during crisis capacity. Please utilize the strategies in this document, as appropriate, to conserve PPE supply. The document can be found at: https://health.mo.gov/living/healthcondiseases/communicable/novel-coronavirus/pdf/ppe-usage.pdf.

Important Information Regarding State and Federal Waiver Implementation for the Nurse Assistant Training Program

SLCR has issued guidance for the implementation of federal and state waivers related to the training and certification of nurse aides. Please read through this important guidance. Questions regarding these waivers and the nurse aide certification process should be directed to CNARegistry@health.mo.gov.

Please see the Nurse Aide Registry Waiver Implementation 4-7-2020 for details.

COVID-19 Reporting of Confirmed and Presumptive Cases

The Department of Health and Senior Services issued guidance regarding reporting of confirmed and presumptive COVID-19 cases. The guidance can be found at: https://health.mo.gov/emergencies/ert/alertsadvisories/index.php.

Effective immediately, long term care communities must report these cases directly to DHSS utilizing the Disease Case Report (CD-1 Form). The CD-1 form can be accessed at https://health.mo.gov/living/healthcondiseases/communicable/communicabledisease/cdmanual/pdf/CD-1.pdf.

There are two methods of communicating this information: fax or Secure File Transfer Protocol (SFTP). The information reported will be communicated with the Local Public Health Agency (LPHA). Long term care communities may continue to reach out directly to their respective LPHA as well.

Please see the Health Update for details.

Resident Advocate Newsletter April 2020

The April 2020 Resident Advocate is now available.

The Resident Advocate provides:

  • Information on residents’ rights and care issues
  • News and updates on national policy
  • Self-advocacy tips for obtaining person-centered, quality care

This issue includes updates on the coronavirus disease (COVID-19) and suggestions for staying engaged and advocating for yourself to continue to receive the care you deserve. This issue also features an article on COVID-19 prevention tips and ideas to stay connected with friends and family during isolation.

This newsletter is a great resource to share with long-term care residents. Nursing home staff, long-term care Ombudsman programs, family members, and other advocates are encouraged to forward this newsletter to residents or print and share copies with residents. Download this issue or past issues from this webpage.

NOTE: The Resident Advocate newsletter is usually mailed free of charge to residents of nursing homes, assisted living facilities, board and care facilities, and individuals receiving long-term care in their home or community. However, because of COVID-19, this issue is only being offered virtually.

Important Information Regarding 1135 Waiver Implementation for Pre-Admission Screening and Resident Review (PASRR)

Background:
On March 25, 2020, the Centers for Medicare and Medicaid Services notified MO HealthNet Division of their approval of a Federal Section 1135 Waiver request to suspend pre-admission screening and annual resident review (PASRR) Section 1919(e)(7) of the Act allows Level I and Level II assessments to be waived for 30 days. All new admissions can be treated like exempted hospital discharges. After 30 days, new admissions with mental illness (MI) or intellectual disability (ID) should receive a Resident Review as soon as resources become available.

Effective April 2, 2020 and until April 25, 2020, certified Skilled Nursing Facilities and Intermediate Care Facilities may follow the process outlined below for new admissions into Medicaid-certified beds.

For an applicant that may require a Level II evaluation (have a qualifying mental illness (MI) or intellectual disability (ID) diagnosis):

  • The applicant may enter the Skilled Nursing Facility (SNF) prior to completion of a Level II PASRR evaluation or Special Admission Category.
  • The Hospital (or other individual completing the paperwork) will send the completed DA 124 C form to the SNF prior to discharge. The SNF should review the client’s information to ensure the Level of Care points (24) would meet prior to admission and ensure they have enough information to determine if they can meet the medical and behavioral needs of the individual.
  • The SNF will submit the entire DA 124 application (DA 124 A/B, DA 124 C and any other supporting documentation) with a Special Admission Category form indicating “Waiver due to COVID-19” to COMRU@health.mo.gov. The SNF should indicate if the client plans to reside at the SNF after 30 days.
  • DHSS recommends that SNFs submit the complete DA 124 application to COMRU within 14 days of admission to the SNF.
  • Once received, COMRU will determine if the applicant meets Level of Care and refer applicants requiring a Level II PASRR screening to DMH.
  • After 30 days, new admissions with mental illness (MI) or intellectual disability (ID) will receive a Resident Review as soon as resources become available.

For completed applications already submitted to COMRU for processing:

  • The applicant may enter the Skilled Nursing Facility (SNF) prior to completion of a Level II PASRR evaluation or Special Admission Category.
  • COMRU will process all pending Level II PASRR applications as Special Admission Category #5 indicating “Waiver due to COVID -19”.
  • Upon discharge, the hospital or other submitter will notify COMRU via email of the following information:  the client’s name, DCN or SSN#, and the receiving SNF information (Name, Telephone number and fax number).
  • The hospital/submitter will ensure a copy of the DA 124 application (DA 124 A/B form and DA 124 C form) are sent to the accepting SNF prior to discharge.

This information should be added to the DA 124 application in process and sent to DMH. For the DA 124 applications that were already referred for Level II PASRR screening, DHSS will notify DMH and Bock & Associates via email of the individuals change in location.

Questions regarding this process can be directed to COMRU@health.mo.gov. The DA 124 application (DA 124 A/B form, DA 124 C form and Special Admission Category Referral form) can be accessed at https://health.mo.gov/seniors/nursinghomes/pasrr.php.

Transfers Between Hospitals and LTC

The Missouri Hospital Association, Long Term Care Associations and the Department have collaborated to provide guidance on transfers between hospitals and long-term care communities. These documents may be used to help guide decision making during this time.

Please see the documents below for further reference.
Post-Acute Care and Behavioral Health to Hospital Transfer
Hospital to Facility Transfer

Regulation update for 19 CSR 30-82.030

The following proposed rulemaking is published in the Missouri Register effective March 30, 2020:

  • 19 CSR 30-82.030 Assessment of Availability of Beds.

While this particular regulation set has been rescinded under the SLCR rules, facilities still have to comply with following Certificate Of Need regulatory citations regarding the criteria and standards for assessment for the availability of beds:

  • 19 CSR 60-50.450
  • 197.318.1, RSMo.

This rule only outlined the procedures the SLCR was to follow when determining for the Missouri Health Facilities Review Committee whether or not a need existed in a particular locale for additional Medicaid certified beds. Additionally, the Certificate of Need Program (CON) has established its own regulations and procedures for the criteria in determining approval of long-term care beds in varying localities. Furthermore, the SLCR provides information to the CON program upon request.

Regulation Update Notice 82.070

CNA, L1MA and Insulin Administration Manuals

Due to circumstances resulting from COVID-19, the Assessment Resource Center (ARC) is currently closed for ordering CNA, L1MA and Insulin Administration manuals. Until further notice, the Health Education Unit will be providing the manuals through an email request.

Please submit the request for the specific manual and amount needed to Angela.Duvall@health.mo.gov. We will then provide you with instructions and directions on receiving the materials requested. You may also email us at cnaregistry@health.mo.gov for questions.

CDC PPE Calculator Released

The personal protective equipment (PPE) burn rate calculator is a spreadsheet-based model that provides information for healthcare facilities to plan and optimize the use of PPE for response to coronavirus disease 2019 (COVID-19).

Please see the following CDC web page for details: https://www.cdc.gov/coronavirus/2019-ncov/hcp/ppe-strategy/burn-calculator.html

OCR Issues Guidance to Help Ensure First Responders and Others Receive Protected Health Information about Individuals Exposed to COVID-19

OCR Issues Guidance to Help Ensure First Responders and Others Receive Protected Health Information about Individuals Exposed to COVID-19
March 24, 2020

The Office for Civil Rights (OCR) at the U.S Department of Health and Human Services (HHS) issued guidance on how covered entities may disclose protected health information (PHI) about an individual who has been infected with or exposed to COVID-19 to law enforcement, paramedics, other first responders, and public health authorities in compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule.

The guidance explains the circumstances under which a covered entity may disclose PHI such as the name or other identifying information about individuals, without their HIPAA authorization, and provides examples including:

  • When needed to provide treatment;
  • When required by law;
  • When first responders may be at risk for an infection; and
  • When disclosure is necessary to prevent or lessen a serious and imminent threat.

This guidance clarifies the regulatory permissions that covered entities may use to disclose PHI to first responders and others so they can take extra precautions or use personal protective equipment. The guidance also includes a reminder that generally, covered entities must make reasonable efforts to limit the PHI used or disclosed to that which is the “minimum necessary” to accomplish the purpose for the disclosure.

“Our nation needs our first responders like never before and we must do all we can to assure their safety while they assure the safety of others,” said Roger Severino, OCR Director. “This guidance helps ensure first responders will have greater access to real time infection information to help keep them and the public safe,” added Severino.

The guidance may be found at: https://www.hhs.gov/sites/default/files/covid-19-hipaa-and-first-responders-508.pdf

For more information on HIPAA and COVID-19, see OCR’s February 2020 Bulletin: https://www.hhs.gov/sites/default/files/february-2020-hipaa-and-novel-coronavirus.pdf

OCR Issues Guidance on Telehealth Remote Communications Following Its Notification of Enforcement Discretion

OCR Issues Guidance on Telehealth Remote Communications Following Its Notification of Enforcement Discretion
March 20, 2020

The Office for Civil Rights (OCR) at the U.S Department of Health and Human Services (HHS) issued guidance on telehealth remote communications following its Notification of Enforcement Discretion during the COVID-19 nationwide public health emergency.

The Notification, issued earlier this week, announced, effective immediately, that OCR is exercising its enforcement discretion to not impose penalties for HIPAA violations against healthcare providers in connection with their good faith provision of telehealth using communication technologies during the COVID-19 nationwide public health emergency.

The new guidance is in the form of frequently asked questions (FAQs) and clarifies how OCR is applying the Notification to support the good faith provision of telehealth. Some of the FAQs include:

  • What covered entities are included and excluded under the Notification?
  • Which parts of the HIPAA Rules are included in the Notification?
  • Does the Notification apply to violations of 42 CFR Part 2, the HHS regulation that protects the confidentiality of substance use disorder patient records?
  • When does the Notification expire?
  • Where can health care providers conduct telehealth?
  • What is a “non-public facing” remote communication product?

“We are empowering medical providers to serve patients wherever they are during this national public health emergency,” said Roger Severino, OCR Director. “We are especially concerned about reaching those most at risk, including older persons and persons with disabilities,” Severino added.

The FAQs on telehealth remote communications may be found at: https://www.hhs.gov/sites/default/files/telehealth-faqs-508.pdf

The press release on telehealth remote communications may be found at: https://www.hhs.gov/about/news/2020/03/17/ocr-announces-notification-of-enforcement-discretion-for-telehealth-remote-communications-during-the-covid-19.html

The Notification of Enforcement Discretion on telehealth remote communications may be found at: https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html

For more information on HIPAA and COVID-19, see OCR’s February 2020 Bulletin: https://www.hhs.gov/sites/default/files/february-2020-hipaa-and-novel-coronavirus.pdf

CMS QSO Memo Regarding Prioritization of Survey Activities

CMS Memo QSO-20-20-ALL: https://www.cms.gov/files/document/qso-20-20-all.pdf

Infection Control Survey Checklist

CMS is prioritizing surveys by authorizing modification of timetables and deadlines for the performance of certain required activities, delaying revisit surveys, and generally exercising enforcement discretion for three weeks. During this three-week timeframe, beginning March 20, 2020, only the following types of surveys will be prioritized and conducted:

  • Complaint/facility-reported incident surveys: State survey agencies (SSAs) will conduct surveys related to complaints and facility-reported incidents (FRIs) that are triaged at the Immediate Jeopardy (IJ) level. A streamlined Infection Control review tool will also be utilized during these surveys, regardless of the Immediate Jeopardy allegation.
  • Targeted Infection Control Surveys: Federal CMS and State surveyors will conduct targeted Infection Control surveys of providers identified through collaboration with the Centers for Disease Control and Prevention (CDC) and the HHS Assistant Secretary for Preparedness and Response (ASPR). They will use a streamlined review checklist to minimize the impact on provider activities, while ensuring providers are implementing actions to protect the health and safety of individuals to respond to the COVID-19 pandemic.

CMS is disseminating the Targeted Infection Control Survey checklist developed by CMS and CDC so facilities can educate themselves on the latest practices and expectations. CMS expects facilities to use this new process, in conjunction with the latest guidance from CDC, to perform a voluntary self-assessment of their ability to prevent the transmission of COVID-19. The checklist is attached.

Though the contents of the memo and checklist are provided by CMS, DHSS is adhering to the same requirements for all facilities. All facilities should complete the infection control self-assessment.

Child Care Needs Assessment

A state-wide team is working to develop a list of childcare needs for healthcare and other critical staff across the state to ensure that those individuals are able to work. The intent is to try to see if local school districts are able to provide the care. 

The next step is to develop a list of childcare needs from the critical employees. The link below will take people to an online form to fill out if they need childcare in order to be able to work.

https://stateofmissouri.wufoo.com/forms/m1cs1vfl1dde8dt/

Once we have the information gathered, we will create a list of needs by school district to send to each district and see if they are able to help provide care. At this point this is information gathering to see what options might be available.

Please ensure all long term care employees submit this form if they have a need.

SNF Claims Incorrectly Cancelled

From January 26 through February 16, 2020, a software issue caused Skilled Nursing Facility (SNF) claims to be incorrectly cancelled with a message that there was no three day qualifying hospital stay. This issue is corrected. If your claims were incorrectly cancelled, re-bill them in sequential order to receive payment.

Note:

  • Claims need to process in date of service order for each stay for the Variable Per Diem (VPD) to calculate correctly
  • Submit claims in sequence and wait at least 2 weeks before billing subsequent claims
  • Some of the affected claims with older dates of service will require a timely filing exception; enter “Resubmission due to non-qualifying stay” in the remarks field
  • This issue was not caused by the recent implementation of the SNF Patient Driven Payment Model
  • Contact your MAC to receive the Medicare Beneficiary Identifier (MBI) for deceased beneficiaries

MLN Matters Bulletin Revised 3-18 -20 Medicare FFS Respnose to COVID-19