Lead January 6, 2022 - LeadingAge Illinois

Life Plan Communities/CCRCs:
Life Plan Communities December Call Materials Available

Nursing and Rehabilitation:
Updates from CMS Nursing Home Division

Home and Community Based Services (HCBS):
Hospice and Home Health Guidance Released December 29

Other:
Updates to COVID-19 Return to Work and Vaccine Toolkits
TANS and Pendings Update
Listing of HealthChoice Illinois ADT Participants

Top Stories:
Provider Relief Fund Reporting Update
As a reminder, the second Provider Relief Fund (PRF) reporting period covers PRF funds received between July 1 and December 31, 2020. These will include Phase 2, 3 and some of the Nursing Home Infection Control (NHIC) dollars.

You can apply eligible coronavirus expenses and lost revenues from January 1, 2020 through December 31, 2021 to these funds but only if they weren’t reported previously and they weren’t covered by another funding source or required to be covered by other sources. (e.g. PPP or Medicare, etc.) It should be noted that Nursing Home Infection Control PRF can only be used for infection control expenses and not lost revenues. For nursing homes who received these funds will want to divide their expenses into infection control and non-infection control expenses first, in order to maximize the use of these NHIC payments.

Providers have until March 31, 2022 to submit their second period report. However, they should begin compiling their information now. Anyone who has been through this already will tell you that it isn’t easy and you don’t want to leave it to the last minute. LeadingAge encourages providers to start by reviewing the available resources for reporting on the HRSA website prior to and while working on their reports. Here are some highlights of these resources:

PRF Reporting Portal – This is where new reporters will register and where everyone will submit their data for their second report. HRSA includes a number of key resources for reporting at the bottom of this page.
For those who haven’t reported previously, your first step will be to register and the PRF Portal Registration Manualwould be worth reviewing before you start. This information will likely be covered in the Jan 12 HRSA webinar on reporting for new reports.
Once you begin to work your way through the reporting process, you will want the PRF Portal – Reporting User’s Guide– This was updated on December 30, 2021 to reflect changes to the process and portal. It includes tips so you don’t lose data and provides definitions of what information they are looking for in each section While you do not need to complete the entire report in one sitting, it is a good idea to pull together your information before you sit down. HRSA has put together a worksheet to help with this process. It has been updated and now includes tabs for documenting your infection control expenses for NHIC funds. They are called portal worksheets. A link to the worksheets can be found on the HRSA reporting resources page.
Finally, it doesn’t hurt to keep the PDF of the PRF FAQ document handy for questions as you move your way through your report.

Legislative Update
The Illinois General Assembly convened yesterday to kick off the 2022 spring session. It may be one of the only in-person session day this month due to the COVID-19 surge. The January session dates may be held remotely. Several bills have been introduced already and we are tracking all introductions as well as meeting with legislators and stakeholders daily on issues impacting members while pushing for our public policy priorities. We will keep you updated on important issues via The Lead, member alerts, and in the LeadingAge Illinois Advocacy Center, where you can find our 2022 legislative tracker. You can also contact Jason Speaks, director of government relations at any time with questions, feedback, or concerns.

Life Plan Communities/CCRCs:

Life Plan Communities December Call Materials Available
On Thursday, December 16, the LeadingAge National Life Plan Communities Advisory Group met to discuss the prescient topic of Diversity, Equity and Inclusion. The full recording and slides are available in the links provided; these notes also include a rich array of resources shared by the panel.

Nursing and Rehabilitation:

Updates from CMS Nursing Home Division
This week, CMS held a call on nursing home issues. The agenda focused mostly on issues related to the mandate guidance memo plus a couple of other things that were raised. Here are the take home messages regarding the vaccine requirement:

CMS will not answer questions from the states that are under the injunction. “The enforcement guidance issued on December 28, 2021 (QSO-22-07 ALL) does not apply to the following states at this time: Alabama, Alaska, Arizona, Arkansas, Georgia, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Mississippi, Missouri, Montana, Nebraska, New Hampshire, North Dakota, Ohio, Oklahoma, South Carolina, South Dakota, Texas, Utah, West Virginia and Wyoming. State and AO surveyors in these states should not undertake any efforts to implement or enforce the IFC.”
CMS expects the non-enjoined states to become compliant. They reviewed the dates and thresholds. Within 30 days of the December 28 announcement – i.e., by January 27 – 80% of staff should have had at least one dose. By February 27, 90% of staff should be fully vaccinated. Surveyors will not start surveying on this until January 27. If your organization is not at 100% compliance, you must have a plan to get to 100%.
CMS is focusing on whether staff got the shot, not the two week waiting period for the staff person to be officially “fully vaccinated.” For this purpose, fully vaccinated means they had either one J&J or two Pfizer/Moderna shots.
When will the matrix be released for surveyors? There will be clarifications and surveyor matrix for surveyors, probably within the next two weeks.
How will exemptions be looked at by surveyors? Surveyors will ask for a list of exemptions – both approved and pending. We don’t expect there to be a huge number of health exemptions. Of course, NHSN doesn’t take religious exemptions into account. “We don’t count exemptions in the survey process.” There is a time limit on how long surveyors will look at pending exemptions.
Surveyors will look at NHSN data before the survey and ask for similar information when they arrive on site. Those numbers should be roughly the same. If there’s more than a 10% difference, surveyors will look a little deeper. Is there a concern with the data provided by the nursing home? An issue with NHSN reporting? There should not be big differences in the NHSN percentage and the list the nursing home provides.
There’s still a lot of confusion over the definition of “staff.” Participants in the meeting noted that the denominator could differ depending on the definition of who counts as staff. CMS staff said they are looking into this and will determine the best vehicle to use to clarify the definition.
What about new staff? During the first 30 days of a person’s employment, they can start working and caring for residents with one dose. The nursing home is responsible for ensuring the person gets the second dose (if Pfizer or Moderna).

Additional issues discussed:

CMS is doing everything to urge that more residents and staff get boosters. Approximately 61% of residents and 26% of staff have gotten boosters. “You’ll be hearing more from HHS on that.” It was noted by participants that one big barrier is family members not wanting residents to get a booster because they remember the side effects the person had with the primary series.
It’s difficult for nursing homes to access treatments. Each state follows its own process for distributing monoclonal antibodies, remdesivir, and oral treatments. LTC pharmacies have been told they cannot receive these treatments; the supply is limited and there are concerns that all doses won’t be used and they’ll sit on LTC pharmacy shelves. It is very challenging for providers and individual staff to access the treatments. One participant cited the fact that two states distribute them only through Walmart; it can be difficult for staff to get there and fill out the paperwork to get the oral medication. Various solutions were discussed and CMS staff committed to working on a resolution.

Home and Community Based Services (HCBS):

Hospice and Home Health Guidance Released December 29
A recent memo on the implementation of the CMS vaccine mandate with guidance for surveyors had specific instructions for compliance for both home health and hospice providers. These providers should read both the general memo and their provider specific attachments carefully so that they can be in compliance. The first deadline for compliance is January 27, 2022; the second deadline is February 28, 2022. We will continue to provide resources on this memo and please email Mollie Gurian at LeadingAge with any specific questions on the guidance for home health and/or hospice providers.

Other:

Updates to COVID-19 Return to Work and Vaccine Toolkits
With the CMS and CDC new guidance and updates, the following toolkits, policy and procedures and forms have been updated:

COVID – 19 Vaccine Employee Policy
Screening and Monitoring – Return to Work criteria policy and procedure, including new grid from CDC update from 12/23
Sample LOG for vaccine documentation
Sample Religious Exemption Form
Sample Medical Exemption Form

You can find the updates and forms here.

TANS and Pendings Update
LeadingAge Illinois Reimbursement Consultant, Matt Werner, has provided the latest update on Transaction Audit Numbers (TANs) and Medicaid Pendings.

Listing of HealthChoice Illinois ADT Participants
The Illinois Department of Healthcare and Family Services (HFS) has distributed an updated list of HealthChoice Illinois ADT Participants.