MDHHS Releases Information and Invitations for CRCs

This afternoon, the Michigan Department of Health & Human Services (MDHHS) shared an invitation via email to eligible facilities to apply as Care and Recovery Centers (CRCs).

 

MDHHS shared, "Pursuant to recommendations made to Governor Gretchen Whitmer by her appointed Nursing Home COVID-19 Preparedness Task Force, the Michigan Department of Health and Human Resources (MDHHS) will engage eligible Medicaid-certified nursing facilities (NF) to establish Care and Recovery Centers (CRCs). The purpose of CRCs is to provide care for individuals with confirmed COVID-19 who have not met criteria for discontinuation of Transmission-Based Precautions. CRCs operate when hospitals need to discharge residents to manage bed availability and provide an alternative for NFs that do not have the capacity to safely care for residents. NFs that operate a CRC have the physical plant capacity to designate a distinct area for COVID-19 isolation, can dedicate staff to the CRC, and meet other established standards."

 

Eligibility criteria established by MDHHS includes:

• The facility has a rating of 3 or higher in the staffing category of the Centers for Medicare & Medicaid Services' (CMS) Nursing Facility Compare Five-Star Rating.
• The facility is not operating under a Denial of Payment for New Admissions (DPNA) restriction.
• The facility is not designated by CMS in Nursing Facility Compare as a Red Hand Facility, indicating a citation for abuse.
  

MDHHS intent is to establish at least one CRC in each Region.  Award decisions will be made through consultation with MDHHS, the Department of Licensing & Regulatory Affairs (LARA), and the Ombudsman's Office.

 

Questions regarding the CRCs can be directed to MDHHS-CareandRecoveryCenters@michigan.gov.

 

CMS Releases Medicare Accelerated and Advance Payment Guidance

On Thursday October 9th, the Centers for Medicare and Medicaid Services (CMS) released updated Medicare Accelerated and Advance Payment guidance based upon the recently enacted Continuing Appropriations Act, 2021 and Other Extensions Act.  

 

The CMS guidance outlines the following repayment schedule:  

• Repayment does not begin for one year starting from the date the accelerated or advance payment was issued (e.g., the date a skilled nursing facility (SNF) received its payment); 
• Beginning at one year from the date the payment was issued and continuing for 11 months, Medicare payments owed to providers and suppliers will be recouped at a rate of 25 percent;
• After the 11 months end, Medicare payments owed to providers and suppliers will be recouped at a rate of 50 percent for another six months; and 
• After the six months end, a letter for any remaining balance of the accelerated or advance payment(s) will be issued. 
  

If such a letter is issued, SNFs will have 30 days from the date of the letter to repay the balance in full. If payment is not received within 30 days, interest will accrue at the rate of 4.0% from the date the letter was issued, and will be assessed for each full 30-day period that the balance remains unpaid. Information related to Extended Repayment Schedules will be included in these letters. CMS may immediately issue these letters to SNFs who received accelerated or advance payments in error. 

 

In a departure from previous policy, CMS notes that SNFs can submit one or more lump sum payments to pay off all or some of their total balance.  To arrange a lump sum payment, CMS indicates SNFs should contact their Medicare Administrative Contractor (MAC) for more instructions on how to make a lump sum payment, especially if payment will be made after the repayment time frame begins.   

 

For questions related to the Accelerated and Advance Payment Program, CMS has established COVID-19 hotlines at each MAC that are operational Monday through Friday to assist all providers with accelerated or advance payment concerns. Providers can contact the MAC that services their geographic area(s). To locate designated MAC areas, refer to the MAC Contact section of this Fact Sheet document or visit the MAC website. 

 

Additional information can be found in the FAQ document located HERE.   

 

Director Gordon Issues Order Requiring Masks & Restricting Gatherings

Today, Michigan Department of Health & Human Services (MDHHS) Director Robert Gordon released an Emergency Order providing guidance on the requirements for the use of face masks, and restricting the size of gathering in both indoor and outdoor locations.  A poster version of the order was also shared upon release of the order.  This order is in effect through October 30, 2020.

 

It is important to note these orders to not apply to long-term care community settings.  Members should continue to adhere to the orders issued October 6th specific to long-term care.

 

The order applies restrictions on attendance at indoor and outdoor gatherings at residences, limiting at 10 indoors and 100 outdoors.  Indoor gatherings at non-residential settings are also limited to 10 individuals, with exceptions for dining establishments, settings with fixed seating arrangements, and some other settings.  Outdoor gatherings as well are limited to 100 individual, with exceptions provided for settings with fixed seating, some sports or entertainment settings, and outdoor pools.

 

The order also establishes the individual responsible for establishments, businesses, or operations must require individuals entering to wear a face covering, and may not assume an individual entering without a face covering falls within a medical exception.  An individual's verbal representation they fall within a medical exception can be accepted. 

 

Gatherings are prohibited altogether in some settings without the collection of contact tracing information prior to entry, including personal care settings, sports and entertainment settings, gymnasiums and other recreational settings.

Violations of the order carry the levy of monetary civil penalties as well as misdemeanor charges.

 

For questions or concerns please contact Cathy Sunlin at CathySunlin@HCAM.org.

 

October 9, 2020