The Lead April 20, 2021

From the Desk of Karen Messer, President and CEO

Top Stories:
Medicare Sequester Bill Signed and CMS Releases MLN on Sequestration Suspension Continuation
Renewal of Determination That a Public Health Emergency Exists
Opportunity for Members Who Run MLTSS/ISNP Plans to Provide Feedback on Serving Seriously Ill Population
LeadingAge Weekly Updates

Supportive Living:
HFS On-Site Reviews

Home and Community Based Services (HCBS):
Johns Hopkins Recruiting for Study on Home Care Workers and Vaccines

Home Health and Hospice:
April 29 Webinar for Hospice and Home Health Members

Independent Affordable/Subsidized Housing:
CDC, HUD Address COVID-19 Restrictions in Independent Living
HUD to Host Vaccine Webinar for Public Housing

Other:
LeadingAge Members – How Are You Handling Mother’s Day in the Post-Vaccine Environment?

From the Desk of Karen Messer, President and CEO
In our weekly meeting with the Illinois Department of Public Health (IDPH) last Thursday, the Department reported that they will be updating their website with the latest COVID-19 Long-Term Care Data. This week, the Department now has the information live on their website.  On this page, you can view Long-Term Care Facility Share of Total COVID-19 Cases, by Week and other breakdowns. 

The Department has also asked us to share that starting this week they will be opening up vaccine availability to friends and family members of staff and residents of long-term care facilities (outside of the City of Chicago).We will share updates and information as we receive it from the Department. 

With gratitude,

Karen

Top Stories:

Medicare Sequester Bill Signed and CMS Releases MLN on Sequestration Suspension Continuation
President Biden signed the Medicare sequester bill which suspends the 2% Medicare reimbursement cut (“the sequester”) through the end of 2021. This applies to all Medicare billers, including home health, hospices, PACE organizations and NFs. A LeadingAge article with more information is here. Providers do not need to take any action.

Back to top

Renewal of Determination That a Public Health Emergency Exists
U.S. Health and Human ServicesSecretary Javier Becerra extended the Public Health Emergency, for another 90 days, as anticipated.  Specifically, he declared: “As a result of the continued consequences of the Coronavirus Disease 2019 (COVID-19) pandemic, on this date (April 15, 2021) and after consultation with public health officials as necessary, I, Xavier Becerra, Secretary of Health and Human Services, pursuant to the authority vested in me under section 319 of the Public Health Service Act, do hereby renew, effective April 21, 2021, the January 31, 2020, determination by former Secretary Alex M. Azar II, that he previously renewed on April 21, 2020, July 23, 2020, October 2, 2020, and January 7, 2021, that a public health emergency exists and has existed since January 27, 2020, nationwide.”

Back to top

Opportunity for Members Who Run MLTSS/ISNP Plans to Provide Feedback on Serving Seriously Ill Population
LeadingAge National was asked by the Center to Advance Palliative Care if they would share an invitation with some members who run managed Medicaid LTSS plans and/or Institutional Special Needs Plans to participate in a focus group/listening session around improving care for the serious illness population.  See the information below and the flyer for more information. Note the quick turnaround ate to respond is this Thursday, April 22.

Invitation:
The Center to Advance Palliative Care (CAPC) is working with the National Academy for State Health Policy (NASHP) on a project to learn about challenges and opportunities to improving the care of people with serious illness who are enrollees in managed Medicaid plans. As a Special Needs Plan, they believe that your organization may have additional lines of business including managed long-term services and supports (MLTSS) or integrated Medicare-Medicaid plans, and would welcome input from those individuals.  Anyone interested in participating should contact Stacie Sinclair by April 22.  They will then follow-up directly with those contacting us with the calendar invitation.

Back to top

LeadingAge Weekly Updates
LeadingAge National has put together a recap of last week’s activity on issues for various member segments. 

Back to top

Supportive Living:

HFS On-Site Reviews
The Illinois Department of Healthcare and Family Services (HFS) reports that staff plan to resume routine on-site reviews soon.  Since the phased attestation process for long term care providers was discontinued, HFS has developed new criteria to determine when routine on-site reviews can occur.  Below is updated information.

When will my community receive an on-site review?
The following information is based on when HFS finalizes its processes for the resumption of routine on-site reviews.  Routine on-site reviews, such as annual reviews, complaint investigations and follow up reviews for findings of non-compliance may begin after an SLP provider has not had a facility onset or associated case of COVID 19 for 14 consecutive days.  Please note on-site reviews may occur prior to this time if there are immediate health and safety concerns. 

When will my community’s annual review be scheduled?
Supportive living program (SLP) providers that have not had a facility onset or associated COVID 19 case in the last 14 days may be contacted to schedule an annual review.  Due to the length of time since annual reviews have been completed, HFS staff will determine if some providers may skip an annual review year.  For example, if an annual review was previously scheduled for May 2020,  the FY20 annual review will be skipped and an FY21 annual review will be initiated.  If your community was in the middle of an annual review when HFS discontinued on-site reviews in March 2020, that annual review will be scheduled with the provider for resumption.

How far back will documentation be reviewed during an annual review?
HFS will need to complete a record review for all current residents who were admitted since the last annual review.  Since some providers will have an annual review skipped, the number of New Admit reviews HFS will be completing may be larger.  There may also be additional Lag Admit Reviews, which are current residents who were admitted PRIOR to the last annual review, however, due to a lag with admissions appearing in HFS’ system, these people were not reviewed as new admissions at that time.  Some of these Lag Admits will include 2018 admissions.   For example, an SLP’s last annual review was March 2019.  There may have been 2018 admissions who were not included in the New Admit sample at that time.  The March 2020 annual review did not occur due to the public health emergency.  HFS will completed and FY21 annual review in May 2021.  The Lag Admit  review sample will include the 2018 admissions that were not reviewed during March 2019. 

Record review for residents who are NOT new admissions will only examine the most current RAI, ISS/ISP, quarterly assessments.  Other documents may be examined further back if a possible problem is identified, such as medication errors.  The record review sample for these residents is a random representative sample that must include a minimum of 10 residents. 

HFS will review hiring documentation for all current staff hired since the last annual review.  The most recent annual staff training documentation will be reviewed.

HFS will review the most current licensure and certification information for the building.  This includes the kitchen inspection by the local health department, elevator inspection, etc.

HFS will review the most recent resident satisfaction survey, TB Risk Assessment, etc.

Annual Level of Care Evaluations:
Requirements for annual Level of Care Determinations have been relaxed by federal CMS during the public health emergency.  However, HFS still would like to complete as many as possible.  These may be completed separately from an annual review.

When will complaint investigations take place?
SLP providers that have not had a facility onset or associated COVID 19 case in the past 14 days may receive on-site complaint investigations.  These on-site reviews will continue to be unannounced.  Federal CMS has approved flexibility with complaint investigations by allowing desk audits.   All complaints received since March 2020 have been started as desk audits.  HFS states that they appreciate your cooperation with faxing information to staff.  Some complaints also require an on-site review.  These will not be scheduled ahead of time.  When there are multiple complaint investigations pending, HFS staff may complete an investigation for all during a single on-site review, especially when there is overlap with allegations, or if the information required is minimal.  This will make the process more efficient for providers and HFS staff.

When will pending findings of non-compliance be issued?
SLP providers that have not had a facility onset or associated COVID 19 case in the past 14 days may receive findings for previously completed annual reviews and complaint investigations.  These findings will be presented via phone and fax according to HFS normal exit procedures.  Regional Supervisors will combine exits for complaint investigations and annual reviews together if there is an overlap with findings or a very small number of findings.  The goal is to allow a provider to develop and implement one plan of correction if they have the same or similar findings for multiple reviews. This will also reduce the number of follow up reviews required.  For example, if a complaint investigation and an annual review will have shared findings issued for 146.245 c RAI and 146.245 d Service Plan and also a finding for 146.230 b 3 Nursing Follow-up Care with the complaint, it make sense to issue at the same time since there is an overlap of findings and the plan of correction for all of the findings would also probably include in-servicing licensed nursing staff.  Again, the goal is to have a more efficient process for providers and HFS staff.

Will my community be cited for requirements impacted by the COVID 19 pandemic?
HFS plans to be reasonable when determining findings related to requirements that were impacted by COVID 19. This includes but is not limited to untimely fingerprint checks when vendors were closed, expired CPR certification when training with a return demonstration was not being provided and late staff training.  There were also some allowances made during the public health emergency, such as preadmission assessments being completed by phone and allowed as a post screen if completed within 10 days.  Also the use of Temporary Nurse Aides (no longer allowed).   Additionally, communal dining, large group activities and activities outside of the building have not been allowed at various points.

What processes do HFS staff have to follow for an on-site review?
HFS staff completing onsite reviews will be tested for COVID.  They will also complete the assessment required by your community for entry to the building.  HFS staff will have their own PPE.

You should continue to submit reports of facility onset and associated COVID cases to Kara Helton so that HFS can plan/adjust our schedules around outbreaks. 

Back to top

Home and Community Based Services (HCBS):

Johns Hopkins Recruiting for Study on Home Care Workers and Vaccines
Johns Hopkins University (JHU) is conducting a study investigating factors that impact COVID-19 vaccine uptake.  They are looking for individuals who provide in-home care to discuss considerations regarding COVID-19 vaccine awareness, access, and acceptance.  The discussions consist of 90-minute focus groups that are hosted remotely (web-based).  Participants are compensated with a $50 Amazon gift card emailed at the conclusion of the session. Please see this flyer for more information and to sign up.

Back to top  

Home Health and Hospice:

April 29 Webinar for Hospice and Home Health Members
On April 29 at 12 p.m. CST, LeadingAge is hosting an event for hospice and home health members to highlight opportunities and connect members who have joined us through their previous affiliation with VNAA. Join LeadingAge CEO Katie Smith Sloan, LeadingAge staff, and your colleagues for this special event. Register to attend.

Back to top

Independent Affordable/Subsidized Housing:

CDC, HUD Address COVID-19 Restrictions in Independent Living
During a call for LeadingAge and Argentum members, the CDC and HUD staff reviewed COVID-19 guidance, discussed vaccination data, and addressed “reopening” questions from providers of independent living communities serving older adults. With many senior living communities navigating decisions around “reopening” communities, the CDC reemphasized current guidance that requires fully vaccinated people to continue risk mitigation strategies outside of the home or private setting for the time being. Specifically, CDC experts highlighted the importance of mask wearing, avoiding medium and large group gatherings, and avoiding eating or dining activities during which masks cannot be worn. During the call, Richard Cho, Senior Advisor to HUD Secretary Marcia Fudge, previewed a new interagency effort through HUD and the Health Resources and Services Administration (HRSA) to increase vaccine access and take-up among HUD-assisted residents. More information is available here

Back to top

HUD to Host Vaccine Webinar for Public Housing
To help boost COVID-19 vaccine confidence, HUD will host a free webinar “A Vaccine Near You: Community-Based Access Strategies” on Wednesday, April 21 with representatives from HUD, the National Center for Health in Public Housing, four leading Public Housing Authorities and their healthcare partners. Similar to a broader HUD vaccine webinar hosted on April 14, this webinar will focus on housing and healthcare partnerships; recruitment and mobilization strategies; peer-to-peer messaging strategies; innovative vaccine access and distribution models from PHAs across the country, including key considerations for coordinating local access for HUD-assisted populations; and the latest developments with the J&J vaccine as they relate to community collaborations. The webinar will be on Wednesday, April 21, 2021 from 1-2:30 p.m. CST. Please register for this webinar here.

Back to top

Other:

LeadingAge Members – How Are You Handling Mother’s Day in the Post-Vaccine Environment?
The guidance and recommendations on visitation from CMS, CDC, and state policymakers as well as individual provider organization’s policies are changing fast. However, they aren’t the same as they were before the pandemic. Members are considering and creating different ideas, like allowing vaccinated volunteers to enter the community to help support virtual visits; or celebrating “Mother’s Month” instead of Mother’s Day. What are your plans?  Here are a couple of questions LeadingAge National has:

  • Are your residents concerned about a flood of visitors on Mother’s Day?
  • Are you hearing from families with concerns?
  • Have you considered alternatives to Mother’s Day visitation?
  • What plans do you have to celebrate family get-togethers moving forward (Father’s Day, Independence Day, etc.)?

LeadingAge would love to hear from you and share with other LeadingAge members about ideas for managing holidays as communities open up to family and friends.  Contact Gene Mitchell to tell your story and share your ideas!

Back to top