MDHHS Adds Testing Requirements for HFA and AFC Facilities Yesterday October 28, 2020 the Michigan Department of Health and Human Services (MDHHS) issued an Epidemic Order adding requirements for COVID-19 diagnostic testing in homes for the aged (HFA) and larger adult foster care facilities, and modifying requirements for skilled nursing facilities (SNF).
The Order applies to all SNFs, all HFAs, and AFCs licensed to serve 13 or more individuals. In addition to the Order, MDHHS also released a Memorandum outlining criteria and providing some additional information.
Key requirements of the Order include:
To support the testing requirements, MDHHS will provide antigen testing supplies for facilities affected by this order, and has established a system for refilling antigen supplies provided directly by the federal government. Facilities may alternatively develop their own testing program and seek reimbursement; MDHHS will reimburse testing expenses not covered by insurance, sharing a Testing Reimbursement Form providers can utilize to request reimbursement.
HFAs must begin as soon as practicable and not later than November 18, 2020.
AFCs impacted by the Order must begin testing as soon as practicable and no later than November 24, 2020 for testing individuals with symptoms or exposure, weekly testing in facilities with positives, and testing of new residents or staff. AFCs must begin initial testing of all residents and staff, as well as weekly staff testing, by December 2, 2020. However, AFCs must test any resident leaving the facility to spend the Thanksgiving holiday in a residential home or for an overnight stay in the community prior to that resident's departure and upon return to the facility.
MCAL Note: There are many questions and clarifications needed regarding these requirements for HFA and AFCs 13 beds and higher. MCAL is working to get answers from MDHHS as soon as possible. Keep in mind that these testing orders for HFA and AFC 13 beds and higher are not mandated to do so until a few weeks from now.
One answer we do know is that training on use of the Abbott BinaxNOW tests are available HERE. Facilities will also need to have a CLIA Waiver which can be applied for HERE. Facilities should get both of these details in place while we look for answers to other questions.
LARA Extends Deadlines for 1135 Waiver Temporary Staff and NAs Pending Testing The Department of Licensing & Regulatory Affairs (LARA) intends to issue a notice extending the previous November 1, 2020 deadline that was applied to nurse aides pending testing, and supporting the Centers for Medicare & Medicaid Services (CMS) 1135 Waiver until January 21, 2021. LARA requires Nurse Aides (NA) in Michigan to have completed an approved Nurse Aide Training program, successfully complete the NA test, and receive their Registry. The message from LARA reinforces that staff members interested in being Nurse Aides should be enrolled in a training program as soon as possible.
Under the CMS 1135 Waiver, providers may utilize temporary staff to complete specific tasks, given they have been trained and deemed competent to complete their assigned tasks. As of today, the 1135 Waiver is in effect until January 22, 2021.
It is HCAM's recommendation that providers utilizing temporary staff not give them a title of "nurse aide" to avoid confusion with the LARA requirements, and enroll them in an approved Nurse Aide Training Program at the earliest convenience.
COVID Vaccination Distribution Registration Deadline Extended The deadline for long term care facilities (nursing facilities, Homes for the Aged, Adult Foster Care, and all other assisted living settings) to sign up to participate in the Pharmacy Partnership for Long-Term Care Program has been extended to Friday, November 6, 2020.
As of this week, approximately 260 Michigan nursing facilities have not registered. HCAM urges members to review the options and register before the deadline. Facilities who are not registered in the CMS database for COVID vaccination distribution will not be offered priority distribution when a vaccination is available, coordinated through local health departments. The Michigan Department of Health & Human Services (MDHHS) has shared that all COVID vaccinations provided to Michigan residents must be documented in the Michigan Care Improvement Registry (MCIR). Inclusion in MCIR will allow providers to easily determine who has received vaccination doses and who may be due for the second dose post admission. Facilities who have not yet registered for use of MCIR should begin this process now. To register, go to the MCIR long term care webpage and scroll to the bottom of the page.
The national vaccine distribution program for long term care residents is being used to register for COVID-19 vaccination distribution. The Centers for Medicare & Medicaid (CMS) and the Centers for Disease Control & Prevention (CDC) have shared that distribution will begin immediately when a vaccine is ready for distribution, with long term care residents prioritized for vaccination. Health care workers are prioritized as Tier 1A, with long term care residents prioritized as Tier 1B.
Long term care facilities will have four options to select from:
Due to the cold-chain storage and reporting requirements, HCAM/MCAL recommends members choose either CVS or Walgreens as your primary distribution choice, or at least as your secondary if choosing your long term care pharmacy as your first choice.
Long term care facilities must register with the CDC on how they want to receive and administer the COVID-19 vaccine when it becomes available. Nursing homes register via NHSN, while assisted living communities and other congregate settings sign up through an online survey.
Upgrade to NHSN Level 3 Access to Meet Required Reporting In an updated memo from the US Department of Health & Human Services (HHS), reporting the point-of-care (POC) testing results is now required as an element of the National Healthcare Safety Network (NHSN) system. The HHS memo identifies that "CMS-certified long term care facilities shall submit point-of-care COVID-19 testing data, including antigen testing data, to CDC's NHSN." To report POC test results to NHSN, facilities must upgrade from SAMS Level-1 access to SAMS Level-3 access. While this new requirement goes into effect immediately, CMS has shared that enforcement discretion will be utilized until November 20, 2020 to allow time for facilities to make the upgrade from Level-1 to Level-3.
Facilities must immediately take action to upgrade from Level-1 to Level-3 to avoid enforcement penalties and to meet this new requirement. This process can take up to four weeks, so do not delay.
To facilitate upgrade to SAMS Level-3:
Alternatively, facilities can email nhsn@cdc.gov with the subject line "Enhancing Data Security" to begin upgrading their SAMS access to use this Pathway.
LARA Licensure Infection Control Surveys Have Begun Earlier this summer, the Department of Licensing & Regulatory Affairs (LARA) shared their plan to implement consultative infection control survey activity as a means of supporting providers. These surveyors would originate out of LARAs Facility Licensing Division, allowing them to offer consultative guidance without citations. These initial surveys will be scheduled in advance with the facility and be conducted with a short onsite survey combined with offsite policy review. Survey exit will include a summary of recommendations and resources for follow-up.
MDHHS Updates SNF Testing Reimbursement Guidance & Visitation Infographic, Adds Link to County Data Yesterday, the Michigan Department of Health & Human Services (MDHHS) updated the COVID Testing Reimbursement Guidance document to reflect that costs related to utilizing Point of Care (POC) Antigen testing would be eligible for specimen collection, but not testing kit costs. In support of testing, MDHHS has begun distributing antigen testing kits to facilities at no charge, hence providing the kits and reimbursing facility staff only for the specimen collection.
MDHHS has also updated the recently released Visitation Infographics to provide additional clarity regarding testing requirements for visitors. A link to the MDHHS County Risk designations updated daily and utilized to determine indoor visitation can now be found at the top of the MI Safe Start webpage.
The association recommends that members incorporate routine checks of three websites to manage testing requirements and visitation:
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