HHS Announces $2 Billion Provider Relief Fund Nursing Facilities Incentive Payment Plans
Today, the U.S. Department of Health and Human Services (HHS), announced the details of the $2 billion Provider Relief Fund (PRF) performance-based incentive payment distribution to nursing facilities. This distribution is the latest fund release in the previously announced$5 billion in planned support to nursing facilities grappling with the impact of COVID-19. Last week, HHS announced disbursement of $2.5 billion in payments to nursing facilities to assist with COVID-19-related expenses for testing, staffing, and personal protective equipment (PPE) needs.
To qualify for payments under the $2 billion incentive program, each facility must have an active certification as a nursing facility or skilled nursing facility (SNF) and receive reimbursement from the Centers for Medicare & Medicaid Services (CMS). Facilities must also report to at least one of three data sources that will be used to establish eligibility and collect necessary provider data to inform payment. These data sources include Certification and Survey Provider Enhanced Reports (CASPER), Nursing facility Compare (NHC), and Provider of Services (POS).
The incentive payment program is scheduled to be divided into four performance periods (September, October, November, December), lasting a month each with $500 million available to nursing facilities in each period. All nursing facilities meeting the qualifications will be eligible for each of the four performance periods. Nursing facilities will be assessed based on a full month's worth of data submissions, which will then undergo additional HHS scrutiny and auditing before payments are issued the following month, after the prior month's performance period.
Using data from CDC, HHS will measure nursing facilities against a baseline level of infection in the community where a given facility is located. CDC's Community Profile Reports (CPRs) include county-level information on total confirmed and/or suspected COVID-19 infections per capita, as well as information on COVID-19 test positivity. Against this baseline, facilities will have their performance measured on two outcomes:
- Ability to keep new COVID infection rates low among residents.
- Ability to keep COVID mortality low among residents.
To measure facility COVID-19 infection and mortality rates, the incentive program will utilize data from the National Healthcare Safety Network (NHSN) LTCF COVID-19 module.
Incentive payments will be subject to the same Terms and Conditions applicable to the initial infection control payments announced last week.
MDHHS Releases POC Antigen Testing Guidance
This afternoon the Michigan Department of Health & Human Services (MDHHS) released updated guidance on the use of Point of Care (POC) COVID Antigen Testing. The guidance aligns with guidance released by the Centers for Medicare & Medicaid Services (CMS) and the Centers for Disease Control & Prevention (CDC) last week, supporting the use of antigen testing in the nursing facility setting.
Guidance is included for the use of antigen testing in nursing facilities in the following categories:
- Testing of symptomatic residents and healthcare provider (HCP)
- Testing of asymptomatic residents and HCP in facilities as part of an COVID-19 outbreak response
- Testing of asymptomatic HCP in facilities without a COVID-19 outbreak as required by MDHHS and CMS recommendations.
In addition, MDHHS provides clarification that negative antigen test results do not require confirmation with a molecular (PCR) COVID test unless there is a high pretest probability of positive results. Examples could include an individual who is symptomatic or has had a known high risk exposure to a COVID positive individual, yet tests negative with an antigen test. In these types of cases, molecular testing to confirm would be considered appropriate. The CDC has revised their terminology to indicate that negative test results are now called "Presumed Negative."
Reporting guidance for antigen testing is also included, indicating that all positive test results must be reported by phone or fax to the local health department within 4 hours of identifying the result or via electronic laboratory report to the Michigan Disease Surveillance System. Test report submission must also include demographics for each case including name, address, telephone, test result, test type, testing dates, age, sex, race, ethnicity and symptoms for the case (if present).
HCAM recommends providers develop internal protocols and policies on testing and reporting prior to the use of a CMS distributed POC antigen testing unit. In discussions with the Michigan Department of Licensing & Regulatory Affairs (LARA), they have made it clear that surveyors will be reviewing the use of POC antigen testing, documentation, and reporting during survey activity.
CMS Launches Care Compare, Transitions Nursing Home Compare
Today, the Centers for Medicare & Medicaid Services (CMS) launched Care Compare, a streamlined redesign of eight existing CMS healthcare compare tools available on Medicare.gov. Care Compare provides a single user-friendly interface that patients and caregivers can use to make informed decisions about healthcare based on cost, quality of care, volume of services, and other data. With just one click, individuals can find information that is easy to understand about doctors, hospitals, nursing homes, and other health care services instead of searching through multiple tools.
CMS has also provided resources and tools to assist in navigating the new Care Compare site as well as other CMS data sites. These include:
The transition from Nursing Home Compare to Care Compare includes all the previously reported data and icons, however presented in an updated manner. Care Compare has been designed to interface seamlessly for mobile & tablet users. As of this time, the current Nursing Home Compare website is still functional. It is unclear if that site will be eliminated in the future.
Medicaid Adjusts September QAS Payments
MDHHS has notified Medicaid providers of an adjustment to the September Quality Assurance Supplemental (QAS) payments. The adjustments reflect a change in the number of Medicaid days of care provided during the state fiscal year 2020 when we experienced decreasing occupancy due to the pandemic. This adjustment is similar to the August payment change to reflect less Medicaid days of care provided. The information about your facility payments is available in Archived Document. Below is a paragraph from the cover letter explaining the change. Please note this change was not due to write-off of uncollected provider tax funds from delinquent facilities. It just reflects fewer Medicaid days of care provided.
"Providers should access their Archived Documents folder within CHAMPS for their provider specific notice "Quality Assurance Supplement Notice sent on 09/02/2020". The provider specific notice discloses the provider's adjusted monthly payment amount for September. This amount was reduced due to updated data. If you feel your amount is low the reconciliation in January will correct any issues you might see.
"Important Note: The automated letter mentions future payment however that is incorrect. This change will only impact September 2020 payments. Sorry for the confusion."
MDHHS Releases Guidance For COVID Stimulus Funds Impact on Cost Reports
Today, the Michigan Department of Health & Human Services (MDHHS) released guidance in L 20-58 to clarify the process for adjustments to the Medicaid Nursing Facility cost report to account for expenses from gifts and grants that are not from an endowment.
Adjustments to the cost report to remove expenses for grants and gifts are required when the grant or gift is not from an endowment. If the grant or gift is from an endowment, providers are not required to make adjustments to the cost report to remove the expenses. An endowment is defined as an endowment fund under the Michigan Uniform Prudent Management of Institutional Funds Act (Michigan Public Act 87 of 2009).
To ensure consistent and prospective application of policy, these changes are effective for cost reporting periods beginning on or after October 1, 2020.
For questions or concerns please contact Cathy Sunlin at CathySunlin@HCAM.org.
Sept. 3, 2020