BCHS Update On Nurse Aide Temporary Registration and 1135 Waiver of Nurse Aide Training
Yesterday, July 28 2020, the Bureau of Community & Health Services (BCHS) shared guidance regarding testing of nurse aides provided with temporary registration during COVID, as well as direct care staff working under the Centers for Medicare & Medicaid Services (CMS) 1135 Waiver of nurse aide training. It is the understanding of the association that if additional extensions to the federal state of emergency are made, additional guidance from BCHS will be shared, extending those associated timelines in alignment with the federal actions.
The following guidance is for individuals that worked as a nurse aide under Executive Orders 2020-13, 2020-49, and 2020-82, in which the test requirement was waived and nurse aide candidates offered a temporary registry. In accordance with the Code of Federal Regulations (483.35(d)), applicable CMS 1135 waiver, and the Michigan Public Health Code (MCL 333.21907), these individuals will be allowed to continue to work as a nurse aide until November 1, 2020. By November 1, 2020, 11:59 pm, these individuals must pass the required examination and become a certified nurse aide to continue working as a nurse aide after this date.
Members should note that the above language does not offer the ability of individuals working under the CMS 1135 Waiver the opportunity to forgo completion of a nurse aide training program and simply test to receive a Michigan Nurse Aide Registry.
For other individuals and applicants not referenced above, the department will continue to apply CFR 483.35(d). This federal requirement allows a facility to employ an individual as a nurse aide for no more than 4 months unless that individual has completed a training and competency evaluation program.
For questions regarding this communication, please contact BCHS-CNA-Registry@michigan.gov.
Patient Pathways Platform (P3)
AHCA launched a new data program to assist nursing facilities with Medicare PDPM stays. To better understand your market patient mix and discharge practices and hone your clinical competencies and programming to deliver high-value care under PDPM, get P3© today. For more information and to purchase P3©, visit P3.ahcancal.org. For more information on this program click HERE.
P3© is a SNF-centered report using hospital and SNF claims to track patient flow and availability in your market area, broken out by clinical categories relevant to the Patient Driven Payment Model (PDPM). The format of the P3© report is an Excel workbook with four data tabs:
- Hospital Referral Data: shows discharge patterns from the top five hospitals by volume in your market, state and national benchmarks, the top SNFs receiving patients from the top five hospitals in your market, the top five hospitals referring to your facility by volume
- SNF LOS and Referral Data: shows the LOS for your facility compared to state and top SNF benchmarks as well as a summary of what settings your facility discharges patients to
- Market PDPM Data: shows your market's hospital discharge volume by PDPM category
- Top Hospital PDPM Data: shows hospital discharge volume by PDPM category for the hospital from which you receive the most referrals
In order to access P3©, you must be an AHCA/ NCAL member, and you must be registered for LTC Trend Tracker. If you are a member who is already registered in LTC Trend Tracker, you may simply go to the AHCA/NCAL Data Solutions platform, datasolutions.ahcancal.org, log in using your LTC Trend Tracker credentials, then select and pay for subscription to the SNFs you are interested in. The annual subscription is $750 and allows for five users and provides four quarterly reports for one facility. Additional reports can be purchased at an additional cost.
MDHHS Requests Long Term Care Facilities Register Now in MCIR to Prepare For COVID Vaccinations
The Michigan Department of Health and Human Services (MDHHS) is preparing for the COVID-19 vaccine that is expected to be available in the near future. Long term care (LTC) facility residents and direct contact staff will be considered a high priority for vaccination. It will be essential that all COVID-19 vaccine administration to your LTC residents and staff is reported to the Michigan Care Improvement Registry (MCIR), Michigan's Immunization Information System. MDHHS is requesting that your facility be enrolled in MCIR now in order to leverage the upcoming influenza season and learn the vaccination reporting process when administering flu vaccine.
By registering now, MCIR staff can assist with the registration process and MCIR system training needed to prepare your staff for the reporting of influenza vaccinations in MCIR, which will be a precursor to the reporting of COVID-19 vaccinations. The process has several steps before training can commence and include the following:
1. Completion of the MCIR User Agreement, available on the MCIR.org website.
2. Creation of a MILogin account. NOTE: MILogin is used to access many MDHHS applications (such as the CHAMPS Medicaid system) so some LTC staff may already be registered users of MILogin and do not need to reregister in MILogin.
3. Creation of a MCIR account including the establishment of a MCIR Site Administrator for your facility.
To begin, complete the MCIR User Agreement and fax it to 517-763-0370 and the MCIR Support Services Staff will work with you as needed to complete steps 2 and 3. Email communications from MCIR Support Services will be from their email address: MDHHS-MCIRHelp@michigan.gov. After this has been completed, your Regional MCIR office will contact you to discuss vaccination reporting and training. Should you have questions concerning the MCIR User Agreement or other questions before beginning the process, please visit the MCIR.org regional site page to locate your Regional MCIR office contact information.
If you are already a registered MCIR user, you will be contacted soon by your Regional MCIR office to be sure that your MCIR User Agreement and contact information is up to date, and to inquire if current LTC staff require refresher training on Site Administrator function, how to maintain a Roster for your facility, and how to perform person searches and/or record vaccinations.
It will be especially important this flu season to vaccinate Michiganders against flu to prevent hospitalizations and reserve our health care resources for COVID-19 response. I invite you to begin working with us now to allow time for your staff to become knowledgeable about MCIR and be prepared for the upcoming flu season and COVID-19 vaccines when available.
For questions or concerns please contact Cathy Sunlin at CathySunlin@HCAM.org.
July 29, 2020