The Lead October 23, 2020 - LeadingAge Illinois

Life Plan Communities / CCRCs:
Member Spotlight: Providence Life Services-Park Place of Elmhurst

Nursing and Rehabilitation:
IDPH Extends Emergency Rules on Discharges
Important Message from CMS to Partner with QIO’s
Toolkit on State Actions to Mitigate COVID-19 Prevalence in Nursing Homes

Independent Affordable/Subsidized Housing:
Affordable Housing Update

Other:
Overview of Testing for SARS-CoV-2 (COVID-19)
Using Eye Protection

Top Stories:

Updated Guidance Defining Exposure to COVID-19
The CDC issued updated guidance to clarify the amount of time it would take for someone to be considered a close contact exposed to a person with COVID-19. The updated guidance now defines a close contact as someone who has spent a cumulative total of 15 minutes or more, in a 24-hour period within six feet of an infected person. Previous guidance defined a close contact as someone who spent at least 15 consecutive minutes within 6 feet of a confirmed case.

Holiday Gathering Guidance
The CDC has guidance on holiday gatherings. They are also considering how they can assist providers in determining how to safely manage holidays and leaves of absence among nursing home residents. Click here for the guidance.

Provider Relief Fund Updates
We have a few updates today on the Provider Relief Fund (PRF).

CARES Act Funding:
The Illinois Department of Healthcare and Family Services (HFS) would like to remind providers to apply for CARES Act funding through the HFS portal that closes October 31. See the previous provider notice for more information.

Video:
The Health Resources and Services Administration and Department of Health and Human Services (HHS) released a provider-focused video on the Provider Relief Fund. It suggests HHS created the fund, rather than Congress.

Phase 2 and 3 Clarifications and Unvalidated Assisted Living TINs:
LeadingAge Assisting with Assisted Living TIN Validation: LeadingAge received an update from HHS on the status of Assisted Living TINs pending validation from both Phase 2 & 3, which is roughly 524 ALs currently. LeadingAge and other senior living associations will be assisting HHS in validating these outstanding AL TINs. These TINs have been validated with the IRS and CMS data but not state data.

Phase 2 & 3 applicants eligible for 2% and add-on once validated:
All providers who applied in Phase 2 and are still awaiting their TIN being validated, are still in the queue to apply for Provider Relief Funds but essentially will complete the Phase 3 application once validated. Once their TIN is validated, they should be sent an access code to complete the Phase 3 application, which includes the reporting of 2019 and 2020 expense and revenue data. This will then make those applicants not only eligible to receive their full 2% of patient care revenue but also potentially an add-on payment.

If providers’ TINs are approved but the application does not ask for the 2019 and 2020 expense and revenue information, these providers should contact the Provider Support Line at 866.569.3522 who can walk them through cancelling their Phase 2 application so they can complete the Phase 3 application. This affords an opportunity to not only receive the 2%, but also a potential add-on payment.

Applications will still need to be submitted by November 6, which is the Phase 3 deadline.

Phase 4 Application Being Discussed:
HHS has noted they are working on a Phase 4 application process, but offered no additional details at this time, as its terms are still under discussion. Nicole Fallon at LeadingAge estimates about $25 billion left in the Provider Relief Fund after Phase 3.

Provider Relief Fund Nursing Home Infection Control Incentive Payments:
LeadingAge highlighted the new developments about the Infection Control Incentive Payments for nursing homes under the Provider Relief Fund on a recent LeadingAge Coronavirus Call.

HHS Partners with CVS and Walgreens to Provide COVID-19 Vaccine to Long-Term Care Facilities
The U.S. Department of Health and Human Services (HHS) held a conference call late Friday afternoon to announce a partnership with CVS and Walgreens to provide, when available, the COVID-19 vaccine to long term care and congregate settings nationwide. LeadingAge Illinois attended the call.

The announcement is part of Operation Warp Speed’s (OWS) goals. The program will provide and administer COVID-19 vaccines to residents of long-term care facilities and congregate settings nationwide with no out-of-pocket costs. Sign up began October 19 and closes October 30.

Here is a summary of the call:

Free of charge to facilities.
Available for residents in all long-term care (LTC) settings, including skilled nursing facilities (SNF), assisted living facilities, residential care homes, and adult family homes.
Available to all remaining LTC staff members who have not been previously vaccinated for COVID-19 (e.g., through satellite, temporary, or off-site clinics).
Available in most rural areas that may not have an easily accessible pharmacy.
Starting October 19, LTC facilities can opt in and indicate which pharmacy partner their facility prefers to have on-site.
Facilities are not mandated to participate in this program and can request to use their current pharmacy contracts to support COVID-19 vaccination.
Those who choose not to participate, need to be prepared to address the aspects of vaccinations.
Nursing homes can sign up via the National Healthcare Safety Network and assisted living and supportive living communities can sign up by completing the RedCap form.
Maggie Elehwany, J.D., senior vice president of public affairs at Argentum, was one of about a handful of persons that asked questions during Q&A and spoke on behalf of assisted living providers.
Paul Mango is the Deputy Chief of Staff for Policy at HHS:
- “This program represents a reinforcement of the overall pandemic response strategy to protect the most vulnerable citizens. We are very close to the goal line here.”
- “Manufacturing is going very well. Tens of millions or safe and effective vaccinations will be available before the end of 2020.”
Major General Christopher Sharpsten. Reported that there will be government-funded ancillary kits (needles, masks, face shields, vaccination cards, etc.) distributed to facilities.
Ruth Link-Gelles, CDC Epidemiologist:
- On-site vaccinations and fulfill reporting requirements, reducing burden on facilities and local health departments.
- CVS or Walgreens will schedule dates with each facility and order supplies, manage onsite administration and report data to local, state and federal agencies within 72 hours.
- All applicable CMS requirements will be followed.

More Information:

Governor’s COVID-19 Briefing Recap
On Monday, Governor Pritzker announced he is resuming daily COVID-19 briefings due to the uptick in positivity rates statewide. It is the first time the Governor has had daily briefings since the spring. As the summer began, he moved to only weekdays and then went to just once per week. This week he had a full week of 2:30 p.m. briefings. LeadingAge Illinois continues to monitor the briefings for information pertinent to members.

“We are now headed into a peak that is beyond, potentially, what we saw in March and April,” said Governor Pritzker on Thursday during a briefing in St. Clair County (Region 4).

Cases:
This month, Illinois set a record high in daily case counts two days in a row. Cases are also increasing nationally and Illinois border states have been labeled as hot spots. There are over 60,159 total cases.

Deaths:
August saw the lowest daily averages of deaths. In May, the average daily death number was 117. The majority of COVID-19 deaths are over the age of 70. There have been over 9,387 COVID-19 deaths.

Testing:

Illinois has completed over 7 million tests since COVID-19 testing began. This comes just two weeks after going over 6 million tests. The state is averaging over 70,000 tests per day. They completed almost 81,000 on Thursday.
BinaxNOW:
- On Wednesday, the first shipments from Illinois to local health departments (LHDs) have been sent carrying more than 170,000 Abbott BinaxNOW tests (rapid antigen tests).
- Shipments will continue on a weekly basis through the end of 2020 from the federal government. Illinois will receive over 3 million.
- Tests are manufactured in Illinois and Abbott hired over 2,000 employees in their new plant in Gurnee.
- The majority are being sent from Illinois to LHDs.
- Illinois will launch a focused pilot in K-12 schools and long term care facilities.
- Federal government is sending shipments directly to long term care facilities and the State has no authority on those direct shipments.

Hospitalizations:
The current daily average of COVID-19 hospitalizations is about 2,000, which is down from 4,800 in May. As of Thursday afternoon, there were:

2,463 in the hospital
525 in ICU
212 on ventilators

Mitigation:
“All of the regions are moving in the wrong direction,” said Governor Pritzker on Wednesday.

Region 1 (Jo Davies, Stephenson, Winnebago, Boone, Dekalb, Carrol, Ogle, Whiteside, Lee, Crawford counties) entered mitigation on October 3. They’ve seen the positivity rate climb to 11.9% and stricter mitigations begin on October 25.
Region 5 (Marion, Jefferson, Wayne, Edwards, Wabash, Perry, Jackson, Franklin, Williamson, Saline, Hamilton, White, Gallatin, Union, Johnson, Pope, Hardin, Alexander, Massac, Pulaski counties) went above the 8% positivity rate to over 9.1% and entered mitigation on Thursday. Hospitalizations continue to rise across the region.
Region 7 (Will, Kankakee counties) and Region 8 (Kane, Dupage) will enter mitigation today.
In mitigation:
- Any facilities that have already advanced to CMS Phase 3 must suspend indoor visitation and off-site outings. Meanwhile, outdoor visitation may continue. Indoor visitation and off-site outings can be resumed 14 days after tiered mitigation for the region is lifted.
- Any facilities that have not yet advanced to CMS Phase 3 are not eligible to advance to CMS Phase 3 until 14 days after tiered mitigation in the region is lifted. Specifically, that means that any plans to begin indoor visitation and off-site outings in association with phase advancement must be postponed until that time. Meanwhile, outdoor visitation may continue.

Vaccinations:
Illinois is updating healthcare providers and LHDs on the Illinois rollout framework. It will evolve as vaccination trials come to a conclusion and the FDA decides on approval. The CDC asked states to provide a vaccination distribution plan. Illinois’ priority is the most vulnerable, frontline healthcare workers, first responders and staff and residents in long term care.

The ICARE program ensures all providers meet the storage and handling requirements. In general, the vaccine will not be mandated, but IDPH will work to provide relevant information on the vaccine and its importance. There will be no cost to individuals for the vaccine, although providers may charge a small fee to administer it to go towards insurance for those covered by insurance. Nobody will be turned away from a vaccination.

Testing Update
Today’s testing update includes information on NHSN reporting, the CMS Testing rule, and IDPH guidance and rules.

One important development is that the Illinois Department of Public Health (IDPH) is in the final stages of developing a policy for testing of their surveyors. Other testing updates include:

Reporting Point of Care Testing Through NHSN:
The U.S. Department of Health and Human Services (HHS) has updated the Lab Data Reporting Requirements document to specify that nursing homes must report point-of-care testing through NHSN. Level 3 access in NHSN is required to report this data.

Providers who do not have level 3 access or are not currently in the process of updating to Level 3 should reach out via e-mail to NHSN immediately (approximately 9,000 nursing homes have level 3 access currently). This does not prohibit a state from continuing to require this reporting take place through a state-specified platform, though CMS and CDC feel confident that most states if not all will transition to this reporting mechanism to satisfy lab data reporting requirements.

Read the updated requirement here (note that the document is updated though the data still reads “June 4”). The CDC plans to cover this topic in an upcoming webinar. Register for these webinars here under “Training.” Notice that the webinars scheduled for this week have been cancelled and a date will be set soon.

CMS reportedly will be enforcing only whether you report positive/negative results; however, CLIA will enforce the full 18 required data elements. Remember that tests must be reported within 24 hours.

CMS Nursing Home Testing Rule:
Comments are due November 2 on CMS-3401-IFC (testing rule). LeadingAge will be commenting on the following topics:

Burden of testing requirements. LeadingAge is hearing that the main barriers to testing are the cost of testing, the significant staff time required to complete testing, and access issues including access to rapid turn-around test results. Routine staff testing (based on county positivity rates) seems to be the biggest pain point, with additional concerns around the low threshold for triggering outbreak testing.
Lack of surveyor testing. LeadingAge sent a letter to CMS on this topic a few weeks ago and plan to include in comments. They advocate for testing of surveyors, since surveyors are in nursing homes including resident care areas, have close contact with both residents and staff, are observing COVID-19 testing, and live in communities (just like our staff) that may have high positivity rates.
Burden of reporting requirements. Point-of-care testing requires additional reporting according to CLIA requirements. CDC now allows for this reporting to be done through the NHSN platform; however, each state is responsible for adopting their own reporting process and are not required to utilize the NHSN option.
Barriers of unnecessary CMPs. LeadingAge has long criticized the use of CMPs. They feel that punishing by taking money away from the provider is detrimental to the quality improvement process.

IDPH Recommendations for Testing Individuals with Signs or Symptoms Consistent with COVID-19 Infection and/or Close Contact with a Confirmed or Probable Case of COVID-19:
The Illinois Department of Public Health (IDPH) has released guidance on Testing for Persons Suspected of Having COVID-19. Click here for the guidance.

BinaxNOW Card Experiences:
LeadingAge is looking for members who would like to discuss their experience with the BinaxNOW cards. They have been hearing a few issues and the communications team would like to get real examples and experience from members. Please contact Janine Finck-Boyle with your experience.

POC Antigen Machine Distribution:
HHS reports that point-of-care antigen machines have been allocated to 1,300 nursing homes that have applied for the CLIA waiver. Each of the nursing homes should have received an email about their distribution. The wave 3 shipments will continue for delivery by November 2.

IDPH Rules:
The emergency rules on nursing home testing expire on October 25, but new rules are being proposed by IDPH. The testing rules will cover all facility settings.

Life Plan Communities / CCRCs:

Member Spotlight: Providence Life Services-Park Place of Elmhurst
Park Place of Elmhurst, a Providence Life Services community, opened its doors in 2012. Providence Life Services has been offering senior living options for over a century. The organization has 10 communities in Illinois, Indiana and Michigan.

Park Place offers independent living, assisted living, memory care, skilled nursing care, and short-term post-acute rehabilitation services. They have private duty services for their independent living residents who need a little assistance. In addition, they also offer hospice and palliative care services on campus. The community has 240 full and part-time staff that serve over three hundred residents every day.

Beth McGowan Welch, executive director at Park Place, has dedicated her professional career to working with elders and has served seniors for almost 25 years. She has also been a longtime leader in LeadingAge Illinois where she has served on cabinets and committees that include presiding over the Nursing Facilities Cabinet for six years. She is currently a member of the CCRC Cabinet.

Beth has been an instrumental part of the Partners in Quality program, each year inviting state and federal legislators into her community to see firsthand what quality older adult care and services looks like. Her most recent grassroots advocacy experience was in a virtual visit with U.S. Rep. Michael Quigley (D-5th District; Chicago). “We need more funding for so many essentials like PPE, testing, staffing, and for doing all the things we need to do to take the best care of our residents,” said Beth to the representative during the visit. She has been very vocal to her legislators throughout her career.

She values the relationships built in a career of caring. “The best part of my job is the honor of getting to know and support my residents,” said Beth. “Coming in a close second is working with amazing people to make a difference for our residents. I am truly blessed.”

Nursing and Rehabilitation:

IDPH Extends Emergency Rules on Discharges
The Illinois Department of Public Health (IDPH) recently extended their emergency rules prohibiting nursing homes from discharging residents for late payment or non-payment. The previous emergency rule expired earlier this month. The extension is effective as of October 2 for 150 days.

Important Message from CMS to Partner with QIO’s
The Centers for Medicare & Medicaid Services (CMS) encourages nursing homes to collaborate with the Quality Improvement Organization (QIO) experts in our mission to increase the performance of the health care system by increasing nursing home quality of care for residents. CMS realizes that responding to the current national health emergency is a top priority in everyone’s minds. CMS acknowledges that nursing homes have had many people come into their facility for varying purposes, from a variety of different federal and state agencies.

Additionally, CMS recognizes that staffing shortages are a priority over everything else because nursing homes are so focused on caring for residents while responding to the pandemic. To learn more about the benefits of partnering with Telligen’s QIO program, read the full CMS Letter of Support. Sign up for Telligen QI Connect™ here before October 31. Contact Lisa Bridwell or Nell Griffin with any questions here.

Toolkit on State Actions to Mitigate COVID-19 Prevalence in Nursing Homes
Click here for the most recent update of the CMS Toolkit on State Actions to Mitigate COVID-19 Prevalence in Nursing Homes. It includes recent information and guidance on vaccinations to prevent infection with influenza virus, pneumococcus, and SARS-CoV-2, the virus that causes COVID-19.

Independent Affordable/Subsidized Housing:

Affordable Housing Update
We have a few updates to share today recapping various meetings and information on affordable housing this week.

LeadingAge Survey:
On October 21, LeadingAge released results of a national survey of affordable senior housing providers. The survey found COVID-19 cases in majority of communities, financial strain, and resident social isolation identified as key concerns. The survey results shed light on the multiple challenges facing affordable senior housing providers.

Low Income Housing Tax Credit:
The low income housing tax credit program is a $9 billion program, by far the largest affordable housing production and preservation program in the country. States have latitude in how they use it through a qualified allocation plan. LeadingAge is working with an organization to conduct a scan of all state plans. A report will be released in the next month.

Congress:
The continuing resolution (CR) runs until December 11. The CR avoids a government shutdown. One of the positives of the CR is the continuation of the IWISH demonstration program. The program is in 40 sites, many of which are LeadingAge members. The program, which is in Illinois as well, was highlighted in several of the Partners in Quality virtual visits LeadingAge Illinois members had with federal legislators. LeadingAge was happy to see the program extended beyond the September 30 sunset, but is working to extend the program further. Progress has been made in meetings with appropriators and HUD would also like to see the program extended.

On the COVID relief front, the next relief package has been nothing short of a rollercoaster. Steven Mnuchin, U.S. Treasury Secretary and U.S. House Speaker Nancy Pelosi (D-California) have been meeting a lot lately and there could be some progress being made on a relief package agreement. U.S. Senate Majority Leader, Mitch McConnell (R-Kentucky), however, has been hesitant in bringing a bill to the Senate floor before the November 3 election. Members are encouraged to keep the pressure on in the Illinois Congressional Delegation.

HUD Service Coordinator Reporting Deadline Extended:
HUD announced a one-month extension of the Standards for Success reporting requirements for 2020. Originally due at the end of October, the reports are now due on November 30. HUD staff will join the regular LeadingAge Housing Advisory Group call on Monday to share more updates about Service Coordinators, including payment and grant extension updates. To join the call, email Juliana Bilowich.

Other:

Overview of Testing for SARS-CoV-2 (COVID-19)
The CDC updated guidance on the appropriate use of testing for SARS-CoV-2 in light of additional testing capacity throughout the country. The CDC updated their COVID-19 testing overview with information on viral and antibody tests.

Using Eye Protection
In our meeting with the Illinois Department of Public Health (IDPH) yesterday, consultants asked to remind providers of the importance of using eye protection. Use of eye protection is recommended in areas with moderate to substantial community transmission. For areas with minimal to no community transmission, eye protection is considered optional, unless otherwise indicated as part of standard precautions. Click here for more information from the CDC.