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November 6, 2024

Coronavirus Resources & Updates

 

Information Released by MAHC on Janunary 18, 2021:

 

FYI - Vaccinator Sites Now Available

 

While we have not received an official notice from the Department of Health & Senior Services, Missouri's COVID-19 Vaccine website (https://covidvaccine.mo.gov/) has been updated to include an interactive map of enrolled vaccinators. Click here to view the map.

 

Please Note - the website states:

The state of Missouri is still experiencing an exceptionally limited supply of COVID-19 vaccines. Before contacting a vaccinator on this map to coordinate your vaccination, please understand that many vaccinators are still awaiting supplies from the federal government.

 

Because vaccinators are listed here does NOT mean:

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Information Released by MAHC on Janunary 13, 2021:

 

Federal Waivers Extended

 

Secretary of Health and Human Services Alex Azar has renewed the public health emergency (PHE) created by the rampant spread of the novel coronavirus COVID-19. This announcement has extended the federal PHE through April 21, 2021 which also extends federal waivers.

 

As a reminder, on November 19, 2020, Governor Parson signed an executive order extending the state of emergency in Missouri through March 31, 2021, thereby extending state waivers.

 

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Information Released by MAHC on Janunary 12, 2021:

 

As a follow-up to my email from yesterday, I wanted to make you aware of our COVID-19 Vaccine coordination efforts among the home care industry.

 

The three Visiting Nurse Associations (VNAs) of Missouri (St. Louis, Kansas City & Southeast) and Kansas City Hospice and Palliative Care have joined together to assist in providing COVID vaccinations to Missouri home care providers (please note: this includes ALL home care providers – Home Health, Hospice, HCBS, Private Duty Nursing and Private Duty/Private Pay).

 

Three of these sites are enrolled vaccinators. On Friday of this week, their name and contact information will be included on a list of eligible vaccinators and made public to all other Phase 1A healthcare providers. As a member of MAHC, we are pleased to be involved in a coordination effort for home care providers and are providing our members with this information early (prior to public release of the full list). We hope this will assist you in getting to the “front of the line” with these certain vaccinators.

 

Any home care agency still needing or interested in receiving the COVID vaccine for their staff may contact one of the organizations listed below. Choose one based on your proximity, as travel to these sites may be necessary (we are still awaiting clarification from the state regarding establishing off-site vaccinator clinics). 

 

You are not obligated to use one of these vaccinators, it is merely information to assist any home care provider that may want/need assistance. The state will be posting a list of all approved vaccinators on Friday and you may choose to instead, contact another provider on that list to partner with. However, it is imperative once you have established an agreement to partner with a Vaccinator for your employees (or a regional group of your employees), DO NOT contact any other Vaccinators. The Vaccinator will be responsible for ordering supply from the state on your behalf. 

 

Also, PLEASE designate ONE primary agency representative to contact your desired vaccinator. DO NOT allow or encourage your staff to contact these agencies individually – it will only slow down the process. Coordination is key to success.

 

If you choose to partner with one of these agencies, please provide the following information in your email request:

 

The organization that you reach out to will provide follow-up details on scheduling vaccinations.

 

Please note: Each vaccinator is doing their best to secure Pfizer and Moderna COVID-19 vaccines, but please note there is no guarantee of vaccine availability, as they are dependent on available shipments from the State of Missouri.

 

Enrolled Vaccinator Providers Volunteering to Assist Home Care Industry:

 

Kansas City Hospice & Palliative Care, Kansas City, MO 64145: 

Primary Contact: Kelli Traylor, Emergency Preparedness Coordinator: KCHCOVIDVaccine@kchospice.org or 816-276-2749

 

Visiting Nurse Association of Kansas City, Kansas City, MO 64145: 

Primary Contact: Martha Becker, COVID Vaccine

Coordinator: info@vnakc.org or 816-627-6247

 

Visiting Nurse Association of Greater St. Louis, St. Louis, MO 63146: 

Primary Contact: Katelyn Viola, Vaccination Coordinator: kviola@vnastl.org or 314-918-7171 ext. 1246

Secondary Contact: Tonya Stacy, Director: tstacy@vnastl.org or 314-918-7171 ext. 1257. 

 

Note: VNA is exploring other locations in the following counties: St. Louis County, St. Louis City, St. Charles County and Jefferson County. In addition, a possible Cape Girardeau location in cooperation with VNASEMO.

 

Visiting Nurse Association of Southeast Missouri, Kennett, MO 63857: 

Primary Contact: Ashlee Collins: acollins@vnasemo.com or 573-919-3249

 

Note: VNA of SEMO is not an approved vaccinator site but is coordinating through VNA of Greater St. Louis as they are considering a clinic at VNA SEMO’s Cape Girardeau office.  

 

 

MAHC would like to publicly thank each of these organizations for their generosity, commitment, time, staff, and willingness to assist the home care industry in vaccinating its workforce!

 

Also, a huge thank you to Lisa Coots and her staff at the Bureau of Home Care & Rehab Standards for their help in coordinating this effort. It really does take a team working together!

 

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Information Released by MAHC on Janunary 11, 2021:

 

On behalf of all Missouri home care providers, the Missouri Alliance for Home Care (MAHC) continues to work daily with the state regarding access to the COVID-19 vaccine.

 

As we previously reported, after MAHC’s diligent advocacy, all home care provider patient facing workforce is included in Phase 1A. 

 

The Division of Community and Public Health within the Department of Health and Senior Services continues to work with federal officials and enrolled vaccinators on the state’s vaccine delivery process. As Missouri continues to finalize delivery of the priority vaccines in long-term care facilities and hospitals, doses should be made available soon to the remaining populations in 1A. Many of the workforce in Phase 1A are employed by an unaffiliated healthcare provider, meaning one who is not affiliated with a hospital/healthcare system or enrolled vaccinator. MAHC has been told that these unaffiliated healthcare providers will soon be receiving a list of enrolled vaccinators to begin the coordination and planning to get their workforce vaccinated.

 

More detailed information should be released from DHSS soon. In the meantime, if you are an unaffiliated healthcare provider, to make sure you are prepared for coordination once you find a vaccinator to partner with, here are a few tips to get you ready:

 

All healthcare workers in 1A should coordinate through their employer to receive a vaccination. Healthcare workers should communicate directly with their employer regarding their desire to be vaccinated and ask their employer to keep them updated on the Vaccination Plan.

 

As an Employer:

 

MAHC receives daily inquiries from home care providers on how to obtain access to the vaccine. The state has requested that our providers demonstrate patience and cooperation during this process. We have been assured that all of Phase 1A will have ample access to the vaccine prior to the state moving to the next Phase. 

 

MAHC will continue to monitor the situation and reach out to DHSS with any issues and/or concerns the home care industry may have or encounter. MAHC is also working on a plan to assist home care agencies by contacting enrolled home care provider vaccinators and discussing possible coordination of setting up one-day clinics or sites for non-enrolled home care providers to vaccinate their staff.

 

Vaccine information that we receive from the state continues to be fluid, sometimes, changing daily and even contradictory at times. We will pass on any official information that we receive as soon as possible. MAHC will continue to be the voice for the home care industry.

 

Also, please find below a link to our Vaccine Newsletter. This newsletter will consist of a variety of information and resources related to the COVID-19 vaccine. This is meant for informational purposes only. Any guidance or opinions included should not be considered an endorsement of any kind by MAHC.

 

Click here to access MAHC’s Vaccine Newsletter.

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Information Released by MAHC on December 18, 2020:

 

 

COVID-19 Vaccine Update for Home Care Workforce

 

MAHC Continues to Advocate for Home Care Industry

 

As we all continue to navigate through the state’s vaccine processes and priorities, I once again have confirmed that all “patient facing” home care healthcare workers (Home Health, Hospice, HCBS, Private Duty) are included in Phase 1A. MAHC worked tirelessly to advocate that the home care provider workforce should be a priority and we applaud DHSS for this decision. Click here to view MAHC’s letter to Dr. Randall Williams, Director, Department of Health & Senior Services.

 

As limited supplies of the vaccine continues to come into Missouri, there are more Health Care Workers in Phase 1 A than vaccine doses. In my last conversation with DHSS today, there was discussion of prioritizing within Phase 1A. DHSS is still analyzing and working on this possibility, but our initial information is that the home care healthcare workforce will be included as a high priority. We will provide any new or updated information as soon as it is available. Also, the state’s vaccine website will include any updates.

 

MAHC, along with the Bureau of Home Care and Rehab Standards staff, also advocated for a coordinated effort in assisting home care agencies that are not enrolled vaccinators to be matched up or given a list of vaccinators within their local areas. We are happy to report that this is currently underway for our Home Health and Hospice agencies and we are told that other healthcare workforce groups will follow a similar process in the near future.

 

Home Health and Hospice – please note that the Bureau of Home Care and Rehab Standards sent a quick survey this week to each Home Health and Hospice agency’s Administrator asking:

 

Please make sure that your home health or hospice agency responds to this survey by Sunday evening, December 20th as this information will be shared with the Bureau of Immunizations who will in turn contact those agencies that still need access to enrolled vaccinators and provide them with local contact information.

 

Please continue to be patient as we address ongoing vaccine questions and as the state continues to work through their processes.

 

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Information Released by MAHC on December 4, 2020:

 

 

Home Care Specific Info - Missouri COVID-19 Vaccination Program

 

MAHC has been receiving many questions from providers related to Missouri’s COVID-19 vaccination program. As the vaccine planning and implementation continues to evolve along with our communications with state leadership for updates and guidance, the following is what we understand, at this point in time, where the home care industry falls within the plan.

 

Phase One – Priority Populations

 

In my verbal communications with DHSS, ALL home care workers with direct patient care (home health, hospice, aides, personal care assistance, etc.) are included as healthcare personnel and staff in Phase 1A.

 

So, how do you get your workforce vaccinated?

 

 

It is certain that home care agencies will encounter varied amounts of administration time in either enrolling and performing as a vaccination provider or determining and coordinating with enrolled providers to vaccinate your staff. Also, we recommend that agencies develop an agency specific/internal decision matrix or prioritization to determine which employees receive the vaccine first in case there are wait or varied times in vaccination providers receiving the vaccines.

 

As MAHC reported on November 30th, the official COVID-19 vaccine website for Missouri – MOStopsCOVID.com – is now available for the most up-to-date information on facts regarding the vaccine for residents and vaccinators. I highly recommend that you visit this website to obtain specific information on Missouri’s plan, vaccination provider enrollment and the Pfizer Vaccine and Moderna Vaccine. 

 

Also, on Thursdays from 3 to 4 p.m., the State of Missouri COVID-19 vaccine planning team will hold weekly meetings to provide state and federal updates on COVID-19 vaccine production and distribution plans. The team will be available to answer questions from providers who have enrolled with the Missouri Department of Health and Senior Services as COVID-19 vaccinators, as well as those who are seeking more information about the process before enrollment. Additional information is available on the Missouri vaccinator website.

 

As much as possible, MAHC will continue to provide up-to-date information to assist home care providers on the COVID-19 vaccine process. I hope this initial information will help your agency in determining your next steps. Let me know if you have further questions in the meantime.

 

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Information Released by MAHC on November 25, 2020:

 

The Division of Senior & Disability Services released a recent memo to provide HCBS providers updated information regarding the COVID-19 Relief Funds reimbursement. HCBS providers may now request reimbursement for all COVID-19 testing expenditures.

 

Reimbursement for testing expenditures is not tied to previously determined allocations. Providers who have reached their allocation through previous submissions may submit additional requests for reimbursement for COVID-19 testing expenditures. Providers should not request reimbursement for testing expenditures that have already been reimbursed.

 

The submission deadline for reimbursement is December 1, 2020. To learn more about the CRF reimbursement process, providers shall visit the designated DHSS CRF website.

 

To submit reimbursement requests, follow the instructions outlined on the webpage.

 

Click here to download the memo.

 

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Information Released by MAHC on November 17, 2020:

 

COVID-19 Relief Funds Extension

 

The Missouri Alliance for Home Care (MAHC) has reached out to the Governor's office related to a large portion of untapped COVID-19 relief funding that was allocated for HCBS providers.

 

One reason for this is continued confusion and lack of clarity from the federal government on how the receipt of other federal dollars may affect the use of these state funds by providers. We are hoping this extension will allow time for further clarity from the federal government. We are grateful to the Governor's office for extending this deadline.

 

In the meantime, MAHC will continue our discussions with the Governor's office and budget leaders on possible alternatives to allow HCBS providers to access the monies.

 

Please click here to view the memo released today from the Division of Senior & Disability Services announcing the extension. Also, based on updated federal guidance, please note the information related to 'interruption of business' and required documentation.

 

 

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Information Released by MAHC on October 30, 2020:

 

See release below from the Department of Health & Senior Services, Division of Community & Public Health, Bureau of Immunizations:

 

Dear Public Health Partner:

 

The Missouri COVID-19 Vaccinator Enrollment program is now open!

Beginning Wednesday, October 28, 2020 at 8:00 a.m., providers will utilize Missouri's Immunization Information System, ShowMeVax, to complete the enrollment process.

The Missouri Bureau of Immunizations has developed helpful tools to guide you through the COVID-19 Vaccinator Enrollment process including provider enrollment FAQ's, a provider enrollment checklist, and the provider enrollment training guide. These tools, along with the link to ShowMeVax, can be found on the COVID-19 Vaccine Information for Vaccinators website at

https://health.mo.gov/living/healthcondiseases/communicable/novel-coronavirus/vaccine.php.

 

Providers who are new to ShowMeVax must submit a signed copy of the Missouri Immunization Registry Memorandum of Agreement (MOA).  If your organization does not have a signed MOA on file, please email the signed MOA to

vfc-smvsupport@health.mo.gov with the subject line "COVID Vaccinator MOA."  If your organization has multiple sites, please include the Immunization Site Demographics Template along with the MOA. These forms are also available on the COVID-19 Vaccine Information for Vaccinators website.

We are looking forward to working with you in the statewide COVID-19 vaccine effort and will assist you in any way we can.  Please do not hesitate to contact us at c19vaxenroll@health.mo.gov if you have any questions regarding the enrollment process.

 

Thank you,

Bureau of Immunizations
Division of Community and Public Health
Department of Health and Senior Services

 

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Information Released by MAHC on October 1, 2020:

Trump Administration Announces $20 Billion in New Phase 3 Provider Relief Funding

Today, under the leadership of President Trump, the U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), is announcing $20 billion in new funding for providers on the frontlines of the coronavirus pandemic. Under this Phase 3 General Distribution allocation, providers that have already received Provider Relief Fund payments will be invited to apply for additional funding that considers financial losses and changes in operating expenses caused by the coronavirus. Previously ineligible providers, such as those who began practicing in 2020 will also be invited to apply, and an expanded group of behavioral health providers confronting the emergence of increased mental health and substance use issues exacerbated by the pandemic will also be eligible for relief payments.

 

Providers can begin applying for funds on Monday, October 5, 2020.

 

"HHS has worked to ensure that all American healthcare providers receive support from the Provider Relief Fund in a fast and fair way, and this new round helps ensure that we are reaching America's essential behavioral health providers and takes into account losses and expenses relating to coronavirus," said HHS Secretary Alex Azar. "We've worked with all of the resources we have across HHS to ensure that America's heroic healthcare providers know they can apply for support."

 

HHS has already issued over $100 billion in relief funding to providers through prior distributions. Still, HHS recognizes that many providers continue to struggle financially from COVID-19's impact. For eligible providers, the new Phase 3 General Distribution is designed to balance an equitable payment of 2 percent of annual revenue from patient care for all applicants plus an add-on payment to account for revenue losses and expenses attributable to COVID-19.

 

Further, HHS recognizes constraints such as the stay-at-home orders and social isolation have been particularly difficult for many Americans. A recent Centers for Disease Control and Prevention (CDC) report found the prevalence of symptoms of anxiety disorder in the second quarter of 2020 was approximately three times those that reported in the second quarter of 2019 (25.5% versus 8.1%); and the prevalence of depressive disorder was approximately four times that reported in the second quarter of 2019 (24.3% versus 6.5%). Our behavioral health providers have shouldered the burden of responding and confronting this expanded challenge triggered by the pandemic. When traditional face-to-face counseling was restricted and new telehealth flexibilities were put in place in response to the pandemic, many behavioral health providers invested in and adopted - PDF telehealth technologies to continue providing patient care. While some Medicare or Medicaid behavioral health providers have already received prior General Distribution payments, others have not. Working with the Substance Abuse and Mental Health Services Administration (SAMHSA), HRSA developed a list of the nation's behavioral health providers now eligible for funding, which includes, for example, addiction counseling centers, mental health counselors, and psychiatrists.

 

Eligibility

 

HHS is making a large number of providers eligible for Phase 3 General Distribution funding, including:

Payment Methodology - Apply Early

 

All eligible providers will be considered for payment against the below criteria.

  1. All provider submissions will be reviewed to confirm they have received a Provider Relief Fund payment equal to approximately 2 percent of patient care revenue from prior general distributions. Applicants that have not yet received Relief Fund payments of 2 percent of patient revenue will receive a payment that, when combined with prior payments (if any), equals 2 percent of patient care revenue.
  2. With the remaining balance of the $20 billion budget, HRSA will then calculate an equitable add-on payment that considers the following:

We know providers want to receive payments shortly after submitting their information. However, this distribution requires cooperation on the part of all applicants. Again, HHS is urging all eligible providers to apply early; do not wait until the last day or week of the application period. Applying early will help to expedite HHS's review process and payment calculations, and ultimately accelerate the distribution of all payments.

 

All payment recipients will be required to attest to receiving the Phase 3 General Distribution payment and accept the associated Terms and Conditions.

 

Application Deadline

 

Providers will have from October 5, 2020 through November 6, 2020 to apply for Phase 3 General Distribution funding. HHS's top priority is ensuring as many providers possible have an opportunity to apply. HHS will continue to host webinars to assist providers through the application process and the call center is also available to address questions.

 

HHS recognizes the multifaceted challenges of this pandemic cannot be won without frontline healthcare providers focused on containing the virus and delivering holistic care. Funding for this Phase 3 General Distribution was made possible through the bipartisan CARES Act and the Paycheck Protection Program and Health Care Enhancement Act, which allocated $175 billion in relief funds to hospitals and other healthcare providers.

 

For updates and to learn more about the Provider Relief Program, visit: hhs.gov/providerrelief.

 

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Information Released by MAHC on August 26, 2020:

 

UPDATE: The deadline to apply for Phase 2 General Distribution Funding has been extended from August 28 to September 13, 2020.

 

Below is the previous notice sent about the Phase 2 General Distribution Funding:

 

August 6, 2020

 

HHS Extends Application Deadline for Medicaid Providers and

Plans to Reopen Portal to Certain Medicare Providers

 

The Department of Health and Human Services (HHS) announced an application deadline extension for the Phase 2 general distribution to Medicaid, Medicaid managed care, Children's Health Insurance Program (CHIP) and dental providers. HHS also plans to allow certain Medicare providers who experienced challenges in the Phase 1 Medicare General Distribution application period a second opportunity to receive funding. Both groups will have until Friday, August 28, 2020 to apply.

 

Medicaid, CHIP, & Dental (Phase 2 General Distribution) Deadline Extension

In June, HHS announced the opening of Phase 2 of the General Distribution - a $15 billion allocation - wherein eligible Medicaid, Medicaid managed care, CHIP and dental providers could begin applying for funding of up to 2 percent of reported revenue from patient care. The goal for this opportunity was to reach the remaining providers participating in state Medicaid and CHIP programs that did not receive funding in the Phase 1, Medicare General Distribution, as well as certain dental providers. The initial deadline of July 20, 2020, was extended to August 3, 2020, based on provider feedback that they learned about the program too close to the deadline and needed more time to complete their application. HHS continues to keep an open line of communication with provider organizations, congressional, state and local leaders, in a collective effort to get the word out about this program, and HHS has learned that a second extension would be beneficial to those providers. By giving providers until August 28, 2020 to apply, HHS is hopeful it has struck the right balance in terms of providing as much flexibility as possible, recognizing the constraints on smaller practices already operating on thin margins with limited administrative staff. HHS will also soon be providing a more simplified application form in response to ongoing dialogue focused on improving the provider experience.

 

Second Chance for Certain Medicare Providers

Starting the week of August 10, HHS will allow Medicare providers who missed the opportunity to apply for additional funding from the $20 billion portion of the $50 billion Phase 1 Medicare General Distribution. In April, to expedite providers getting money as quickly as possible, as they faced the financial hardships stemming from suspended elective procedures and other COVID-19 related impacts, HHS, utilizing the Centers for Medicare and Medicare Services (CMS) payment information, distributed $30 billion directly to Medicare providers proportionate to their share of 2019 Medicare fee-for-service reimbursements. This was part one of the $50 billion Phase 1 Medicare General Distribution which sought to offer providers financial relief equal to 2 percent of their annual revenues. Providers that do not submit comprehensive cost reports with CMS were asked to submit revenue information to a portal to receive the balance of their 2 percent payment of General Distribution funds. Some providers, including many Medicaid, CHIP, and dental providers with low Medicare revenues, did not complete an application by the deadline for this additional $20 billion round of funding. HHS, in its principle of ensuring fairness in the administration of the Provider Relief Fund program, is now giving those eligible providers another opportunity to apply for additional funding. They will have until August 28, 2020, to complete an application to be considered for the balance of their additional funding up to 2 percent of their annual patient revenues.

 

Payments for Providers Who Had a Change in Ownership

As previously noted, HHS relied on 2019 CMS payment data on file to determine automatic payments for $30 billion of the $50 billion Phase 1 Medicare General Distribution. Accordingly, some providers or provider practices that experienced a change in ownership in 2020 missed out on payments as the payments were distributed to the previous owners. Prior owners are required to return the payments to HHS, if they cannot attest to providing diagnoses, testing, or care for individuals with possible or actual cases of COVID-19 on or after January 31, 2020. For program integrity considerations, previous owners are precluded from transferring funds to new owners who may qualify and can attest to providing care for possible or actual COVID 19 cases. HHS did not reissue returned payments to the new owners and instead promised to give new owners a separate opportunity to apply for provider relief funding. That opportunity is now here. Starting the week of August 10, providers who experienced change in ownership challenges may submit their revenue information, along with documentation proving a change in ownership, by August 28 for consideration for Provider Relief Fund payment.

 

Click here for updated information and data on the Provider Relief Fund.

 

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Information Released by MAHC on August 21, 2020:

 

Please find information related to the following:

 

Click here to download today's information.

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Information Released by MAHC on August 11, 2020:

 

Please find information related to the following:

 

Click here to download today's information.

 

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Information Released by MAHC on August 6, 2020:

 

HHS Extends Application Deadline for Medicaid Providers and

Plans to Reopen Portal to Certain Medicare Providers

 

The Department of Health and Human Services (HHS) announced an application deadline extension for the Phase 2 general distribution to Medicaid, Medicaid managed care, Children's Health Insurance Program (CHIP) and dental providers. HHS also plans to allow certain Medicare providers who experienced challenges in the Phase 1 Medicare General Distribution application period a second opportunity to receive funding. Both groups will have until Friday, August 28, 2020 to apply.

 

Medicaid, CHIP, & Dental (Phase 2 General Distribution) Deadline Extension

 

In June, HHS announced the opening of Phase 2 of the General Distribution - a $15 billion allocation - wherein eligible Medicaid, Medicaid managed care, CHIP and dental providers could begin applying for funding of up to 2 percent of reported revenue from patient care. The goal for this opportunity was to reach the remaining providers participating in state Medicaid and CHIP programs that did not receive funding in the Phase 1, Medicare General Distribution, as well as certain dental providers. The initial deadline of July 20, 2020, was extended to August 3, 2020, based on provider feedback that they learned about the program too close to the deadline and needed more time to complete their application. HHS continues to keep an open line of communication with provider organizations, congressional, state and local leaders, in a collective effort to get the word out about this program, and HHS has learned that a second extension would be beneficial to those providers. By giving providers until August 28, 2020 to apply, HHS is hopeful it has struck the right balance in terms of providing as much flexibility as possible, recognizing the constraints on smaller practices already operating on thin margins with limited administrative staff. HHS will also soon be providing a more simplified application form in response to ongoing dialogue focused on improving the provider experience.

 

Second Chance for Certain Medicare Providers

 

Starting the week of August 10, HHS will allow Medicare providers who missed the opportunity to apply for additional funding from the $20 billion portion of the $50 billion Phase 1 Medicare General Distribution. In April, to expedite providers getting money as quickly as possible, as they faced the financial hardships stemming from suspended elective procedures and other COVID-19 related impacts, HHS, utilizing the Centers for Medicare and Medicare Services (CMS) payment information, distributed $30 billion directly to Medicare providers proportionate to their share of 2019 Medicare fee-for-service reimbursements. This was part one of the $50 billion Phase 1 Medicare General Distribution which sought to offer providers financial relief equal to 2 percent of their annual revenues. Providers that do not submit comprehensive cost reports with CMS were asked to submit revenue information to a portal to receive the balance of their 2 percent payment of General Distribution funds. Some providers, including many Medicaid, CHIP, and dental providers with low Medicare revenues, did not complete an application by the deadline for this additional $20 billion round of funding. HHS, in its principle of ensuring fairness in the administration of the Provider Relief Fund program, is now giving those eligible providers another opportunity to apply for additional funding. They will have until August 28, 2020, to complete an application to be considered for the balance of their additional funding up to 2 percent of their annual patient revenues.

 

Payments for Providers Who Had a Change in Ownership

 

As previously noted, HHS relied on 2019 CMS payment data on file to determine automatic payments for $30 billion of the $50 billion Phase 1 Medicare General Distribution. Accordingly, some providers or provider practices that experienced a change in ownership in 2020 missed out on payments as the payments were distributed to the previous owners. Prior owners are required to return the payments to HHS, if they cannot attest to providing diagnoses, testing, or care for individuals with possible or actual cases of COVID-19 on or after January 31, 2020. For program integrity considerations, previous owners are precluded from transferring funds to new owners who may qualify and can attest to providing care for possible or actual COVID 19 cases. HHS did not reissue returned payments to the new owners and instead promised to give new owners a separate opportunity to apply for provider relief funding. That opportunity is now here. Starting the week of August 10, providers who experienced change in ownership challenges may submit their revenue information, along with documentation proving a change in ownership, by August 28 for consideration for Provider Relief Fund payment.

 

Click here for updated information and data on the Provider Relief Fund.

 

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Information Released by MAHC on July 27, 2020:

 

COVID-19 Public Health Emergency Extended

Alex Azar, the Secretary of the Department of Health & Human Services (HHS) signed a 90-day extension of the COVID-19 public health emergency (PHE) on Thursday, July 23,

extending enforcement and payment flexibilities affecting home health, hospice, and other health care stakeholders. The PHE was set to expire on Saturday, July 25.


A PHE expires 90 days after the declaration of one by the Secretary of Health & Human Services, or as long as the secretary deems the emergency to exist. A PHE declaration can be rescinded at any time if the secretary determines the emergency is over.

 

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Home and Community Based Services Provider 

COVID-19 Relief Funds Reimbursement

 

After numerous conversations with the Governor and Treasurer's offices on behalf of our members, we are pleased to see that HCBS Providers will be receiving a portion of the federal Coronavirus Relief dollars.

 

The Division of Senior & Disability Services released the following memo this morning: https://health.mo.gov/seniors/hcbs/info-docs/info-07-20-05.pdf

 

This memorandum is to inform Department of Health and Senior Services (DHSS), Home and Community Based Services (HCBS) providers of a provider COVID-19 Relief Funds (CRF) reimbursement opportunity. 

 

The state has allocated twenty million dollars ($20,000,000) from the Coronavirus Relief Funds for relief to DHSS HCBS Providers. Providers may seek reimbursement for costs associated with necessary COVID-19 expenditures (e.g. PPE, extra staffing costs, etc.) or for loss of revenue associated with business interruption. Claims must occur between March 1, 2020 and December 30, 2020 and may not have been recovered from any other local, state, federal or private source.

 

To learn more about the CRF reimbursement process, providers shall visit the designated DHSS CRF website: https://health.mo.gov/seniors/hcbs/covid-19-provider-relief-funds.php.

 

To submit reimbursement requests, follow the instructions outlined on the webpage. Providers may seek reimbursement up to the allocated amount. This allocation is based on a prorated share of available funding based on the agencies percentage of the total billings from December 1, 2019-February 29, 2020. For information regarding your agency's allocation, email your provider name and NPI to DHSS.CRF@health.mo.gov.

 

Questions regarding this memorandum should sent to Provider COVID-19 Relief email address at: DHSS.CRF@health.mo.gov.

 

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Information Released by MAHC on July 23, 2020:

 

Governor Parson Announces COVID-19 Grant Funds for Non-Profits

 

Yesterday, Governor Parson announced grant funds for nonprofits in the amount of $22 million.  The press release below gives more details or click here for information on who/how/when to apply.

 

GOVERNOR PARSON ANNOUNCES $22 MILLION IN GRANT FUNDS FOR NONPROFITS

 JULY 22, 2020

 
JEFFERSON CITY - Today, Governor Mike Parson announced a new Nonprofit Relief and Recovery Grant that could provide up to $22 million for Missouri nonprofits assisting communities in response to COVID-19.

 

"Missouri nonprofits have been a lifeline for many Missourians throughout the COVID-19 crisis," Governor Parson said. "They have delivered critical support to our citizens, and this grant will ensure that they are able to continue helping those who need it most."

 

The Nonprofit Relief and Recovery Grant was designed to support nonprofits in meeting critical and emergent needs as a result of COVID-19 and to help these organizations maintain their operations despite lower than average donations during the pandemic.

 

"The nonprofit community has been instrumental for many Missourians in this time of uncertainty," Department of Economic Development Director Rob Dixon said. "This program will help magnify those efforts, supporting these organizations even as the pandemic evolves."

 

Organizations eligible for this grant are 501(c)(3) nonprofits, excluding hospitals, schools, and animal charities. Funds can be used to cover hazard pay for direct health care workers, leasing additional space for social distancing, testing costs, program payroll and supply expenses related to increased demand for nonprofit services, direct assistance to individuals and families, and more.

 

The maximum grant request is initially limited to $250,000. Organizations applying must show a direct link between the COVID-19 crisis and their ability to provide services or a significant increase in demand for services by the community. Applicants must also demonstrate incurred costs or anticipated costs between March 1 and November 15, 2020.

The Department of Economic Development will accept applications in two rounds via electronic submission. Round one will be accepted from July 22 to August 14, 2020. Those eligible to apply are nonprofits serving disadvantaged populations whose services are substantially dedicated to addressing critical needs resulting from COVID-19 in the areas of homelessness prevention, job training, food insecurity, at-risk youth services, childcare, and educational support. 

 

Round two will be accepted from August 19 to August 28, 2020. Those eligible to apply are nonprofits providing services not identified in round one that can demonstrate they are suffering from direct and second-order effects of the public health emergency.

 

For more information on the grant program, visit https://showmestrong.mo.gov/.

 

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Information Released by MAHC on July 20, 2020:

 

Attention: In-Home & CDS Providers

 

As a follow-up to my July 2 post (below), please find the official memo released today by DSDS related to the change in their COVID-19 Guidance pertaining to telephone checks:

 

This memorandum provides new billing guidance for health and welfare telephone checks completed during this emergent period. 


 Effective for dates of service on and after August 01, 2020, the following changes are made for health and welfare checks: 

Questions regarding this memorandum should be directed to the Bureau of Long Term Services and Supports (BLTSS) via e-mail at LTSS@health.mo.gov.

 

Click here to access the memo.

 

The COVID-19 Emergency Guidance has also been updated to correspond with the above memo. Providers should review all sections identified as updated for the latest guidelines. https://health.mo.gov/seniors/hcbs/covid-19-provider-info.php

 

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Information Released by MAHC on July 2, 2020:

 

Attention: In-Home & CDS Providers

 

As a HCBS agency model and/or consumer directed services provider, you are aware of the current DSDS COVID-19 Guidance related to Telephone Checks:

 

For state plan personal care participants (agency-model and consumer-directed) receiving services in their home, providers also have the option to conduct telephone checks for participants in order to ensure their health, safety and welfare in these circumstances. (i.e. additional time to go over back-up plans, checking on symptoms prior to sending an aide, general questions related to resource needs during COVID-19 and the stay at home order, and/or the participant is refusing services due exposure risk or there are staffing limitations so multiple phone checks are needed, etc.). These services are in addition to and not in lieu of telephone nurse visits discussed below. Telephone checks should be documented by the provider/vendor by following normal timesheet guidelines. For task, indicate - telephone check. (See separate section for signature guidance). Up to five (5) hours or 20 units per month of personal care can be utilized (above the normal authorization level) for each participant to complete these vital checks.

 

In our conversations with DSDS, we have been informed that they are looking to limit telephone checks to within the currently authorized limit.  At this time, they feel there is not the same need for telephone checks as there was during the initial phase of the pandemic.  Now that everyone has settled into what COVID life looks like, they feel it would be appropriate to pull back on the additional 20 units. If a resurgence would occur and the need would return, they would look into returning to above the authorized limit. 

 

Although not official yet, DSDS is anticipating the change to take effect August 1. In the meantime, please let me know ASAP if you have specific examples of participants that you feel still need that extra time above the authorized amount and we can have DSDS look into those cases and/or reevaluate the decision to pull back.

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Information Released by MAHC on June 22, 2020:

 

Please find attached information related to the following:

 

Click here to download today's information.

 

     _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

 

Upcoming Medicaid COVID-19 Relief Funding Webinar

As reported earlier, the U.S. Department of Health and Human Services (HHS) announced additional distributions from the Provider Relief Fund to eligible providers that participate in the Medicaid program - including the Statewide Medicaid Managed Care program - and Children's Health Insurance Program (CHIP).

HHS is planning two webinars this week for providers to better understand the Medicaid Provider Relief Portal and application process. The webinar, titled "Getting Started With the Provider Relief Fund", are scheduled as follows:

HHS has also posted FAQs on their website providing additional information that providers may find useful. Click here to access the FAQs (please note: the FAQs specific to Medicaid providers starts on page 33 under the heading "Medicaid Targeted Distribution").

 

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Information Released by MAHC on June 12, 2020:

 

Yesterday afternoon, Missouri Governor Mike Parson announced that Missouri will officially conclude phase 1 of the plan to begin re-opening Missouri on June 15, 2020 and will begin phase 2 and fully re-open the state beginning Tuesday, June 16, 2020.  Local ordinances will still apply.  

 

Governor Parson also mentioned in his press conference that he is extending the state of emergency through December 30, 2020, in order to utilize federal CARES Act funding. Extending the state of emergency will also allow continued flexibility in deploying resources around the state as Missouri reopens and recovers from COVID-19. 

 

Therefore, all state waivers that were set to expire Monday, June 15, are now extended to December 30, 2020.

 

MAHC's Board of Directors, Committees and Task Forces will be meeting this summer/fall to discuss what waivers each provider type would like to see become permanent. If you are not currently a member of and are interested in serving on one of MAHC's Committees/Task Forces, click here to download our Committee/Task Force sign up sheet.

 

Below is a copy of the Governor's full Press Release.

 

Thanks

Carol Hudspeth

Executive Director

 ---------------------------------------------------------------------------------------------------

JUNE 11, 2020

 

JEFFERSON CITY - Pending expiration of Phase 1 on June 15, Governor Mike Parson announced today that Missouri will fully reopen and enter Phase 2 of its "Show Me Strong Recovery" Plan on Tuesday, June 16, 2020. 

 

"It is truly incredible to think about how far Missouri has come since March. At that time, no one knew what to expect. There was a lot of uncertainty, worry, and concern," Governor Parson said. "Here we are today, just over 90 days since our first COVID-19 case in Missouri, and I am proud to say we have overcome all of these challenges and more than met our four pillars to reopen." 

 

During Phase 2, there will be no statewide health order. All statewide restrictions will be lifted, though local officials will still have the authority to put further rules, regulations, or ordinances in place.

The decision to reopen was dependent on the four essential "Show Me Strong Recovery" pillars:

Weekly testing in Missouri has increased more than 220 percent from approximately 16,000 test encounters the week of April 20 to over 53,000 encounters the week of May 25. Over the past two weeks, the state has averaged more than 10,000 tests per weekday. 

 

Missouri continues to receive and distribute PPE across the state. Yesterday, the state reached a record PPE shipment, expanding to include not only hospitals, health care facilities, and EMS but also dental offices as more are reopening across the state. Yesterday's shipments included the following:

Missouri has also received national recognition for the use of its PPE marketplace, which helps health care providers with Missouri manufactures and suppliers. Currently, there are over 100 hospitals, 436 suppliers, and 1,567 health care providers, businesses, and other organizations registered in the PPE marketplace. 

 

Regarding hospital capacity, hospitalizations fell by 43 percent statewide from May 1 to June 10. In April, the state converted a hotel into an alternate care site in just 11 days. 

 

Missouri now also has a comprehensive COVID-19 dashboard containing data from across the state on testing, positivity rate, deaths, and hospitalizations. Much of the data is broken down further by county or demographics. 

 

"We have learned and accomplished so much since March. Knowing what we know now, we are much better prepared to deal with COVID-19 going forward, and we are fully confident that Missouri is ready to take the next step," Governor Parson said. 

 

While Missouri will fully reopen on June 16, Governor Parson emphasized the importance of continuing social distancing and practicing proper hygiene to prevent the spread of COVID-19. 

 

"We must remember that COVID-19 is not gone," Governor Parson said. "It is still extremely important for everyone to continue social distancing. Be proactive. Avoid large, congested crowds, and if you can't social distance, take extra precautions to protect yourself and those around you."  

 

"We all know how to do this now, and it is up to us to take responsibility for our own actions," Governor Parson continued. 

 

In preparation of Phase 2, Governor Parson signed Executive Order 20-12 extending the state of emergency in Missouri through December 30, 2020, in order to utilize federal CARES Act funding. Extending the state of emergency will also allow continued flexibility in deploying resources around the state as Missouri reopens and recovers from COVID-19. 

 

Executive Order 20-12 also further extends four previous Executive Orders assisting with Missouri's COVID-19 response through December 30:

Extending these Executive Orders is consistent with the emergency declaration and gives Missourians more time to adjust as the state works through the economic recovery process. To view Executive Order 20-12, click here.

 

Governor Parson was joined today by Missouri Department of Economic Development Director Rob Dixon to share more details about the state's recovery plans as well as a new economic recovery dashboard. 

 

To view Governor Parson's remarks from today's briefing, click here. Pictures will be available on Governor Parson's Flickr page

 

 

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Information Released by MAHC on June 11, 2020:

 

As a follow-up to information from June 9 (below), the following is the information released related to the Medicaid/CHIP Provider Relief Fund Payment Portal instructions and application:

 

Medicaid/CHIP Provider Relief Fund Payment Forms and Guidance

HHS expects to distribute $15 billion to eligible Medicaid and CHIP providers. The payment to each provider will be at least 2 percent of reported gross revenue from patient care; the final amount each provider receives will be determined after the data is submitted, including information about the number of Medicaid patients providers serve. Before applying through the enhanced provider relief portal,  applicants should:

 

Read the Medicaid Provider Distribution Instructions - PDF*

 

Download the Medicaid Provider Distribution Application Form - PDF*

 

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Information Released by MAHC on June 9, 2020:

 

Today, the U.S. Department of Health and Human Services (HHS) released additional information on distribution of the provider relief funds for Medicaid providers that have not otherwise received Provider Relief Funding. This is especially relevant to LTSS and HCBS providers that have been struggling due to increased costs and decreased utilization and hope that this funding can help support sustainability.   We will continue to provide you with more details as we receive.

 

See the announcement below:

 

HHS Announces Enhanced Provider Portal, Relief Fund Payments for Safety Net Hospitals, Medicaid & CHIP Providers

 

Today, the U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), is announcing the distribution of additional relief funds from the Provider Relief Fund to eligible Medicaid and Children's Health Insurance Program (CHIP) providers that participate in state Medicaid and CHIP programs. HHS expects to distribute approximately $15 billion to eligible providers that participate in state Medicaid and CHIP programs and have not received a payment from the Provider Relief Fund General Allocation. HHS is also announcing the distribution of $10 billion in Provider Relief Funds to safety net hospitals that serve our most vulnerable citizens. The safety net distribution will occur this week.

 

"Healthcare providers who focus on treating the most vulnerable Americans, including low-income and minority patients, are absolutely essential to our fight against COVID-19," said HHS Secretary Alex Azar. "HHS is using funds from Congress, secured by President Trump, to provide new targeted help for America's safety-net providers and clinicians who treat millions of Medicaid beneficiaries."

 

HHS is providing support to healthcare providers fighting the COVID-19 pandemic through the bipartisan CARES Act and the Paycheck Protection Program and Health Care Enhancement Act, which allocated $175 billion in relief funds to hospitals and other healthcare providers, including those disproportionately impacted by this pandemic.

 

ENHANCED PROVIDER RELIEF FUND PORTAL

On Wednesday, HHS is launching an enhanced Provider Relief Fund Payment Portal that will allow eligible Medicaid and CHIP providers to report their annual patient revenue, which will be used as a factor in determining their Provider Relief Fund payment. The payment to each provider will be at least 2 percent of reported gross revenue from patient care; the final amount each provider receives will be determined after the data is submitted, including information about the number of Medicaid patients providers serve.

 

The initial General Distribution provided payments to approximately 62 percent of all providers participating in state Medicaid and CHIP programs. The Medicaid and CHIP Targeted distribution will make the Provider Relief Fund available to the remaining 38 percent. HHS has already provided relief funding to over one million providers, and today's announcement is expected to reach several hundred thousand more providers, many of whom are safety net providers operating on thin margins.

 

Clinicians that participate in state Medicaid and CHIP programs and/or Medicaid and CHIP managed care organizations who have not yet received General Distribution funding may submit their annual patient revenue information to the enhanced Provider Relief Fund Portal to receive a distribution equal to at least 2 percent of reported gross revenues from patient care. This funding will supply relief to Medicaid and CHIP providers experiencing lost revenues or increased expenses due to COVID-19. Examples of providers, serving Medicaid/CHIP beneficiaries, possibly eligible for this funding include pediatricians, obstetrician-gynecologists, dentists, opioid treatment and behavioral health providers, assisted living facilities and other home and community-based services providers.

 

To be eligible for this funding, health care providers must not have received payments from the $50 billion Provider Relief Fund General Distribution and either have directly billed their state Medicaid/CHIP programs or Medicaid managed care plans for healthcare-related services between January 1, 2018, to May 31, 2020. Close to one million health care providers may be eligible for this funding.

 

More information about eligibility and the application process is available at https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/general-information/index.html

 

 

The full announcement can be found here: https://content.govdelivery.com/accounts/USCMSMEDICAID/bulletins/28fd559

 

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Information Released by MAHC on June 4, 2020:

 

On June 2, the Department of Health and Human Services (HHS) came out with important guidance on the scope of Covid-19 related expenses that can support the receipt and retention of monies from the Provider Relief Fund.


The guidance offers the following:


The term "health care related expenses attributable to coronavirus" is a broad term that may cover a range of items and services purchased to prevent, prepare for, and respond to coronavirus, including -


Providers may have incurred eligible health care related expenses attributable to coronavirus prior to the date on which they received their payment. Providers can use their Provider Relief Fund payment for such expenses incurred on any date, so long as those expenses were attributable to coronavirus and were used to prevent, prepare for, and respond to coronavirus. HHS expects that it would be highly unusual for providers to have incurred eligible expenses prior to January 1, 2020.

 

The term "lost revenues that are attributable to coronavirus" means any revenue that you as a healthcare provider lost due to coronavirus. This may include revenue losses associated with fewer outpatient visits, canceled elective procedures or services, or increased uncompensated care. Providers can use Provider Relief Fund payments to cover any cost that the lost revenue otherwise would have covered, so long as that cost prevents, prepares for, or responds to coronavirus. Thus, these costs do not need to be specific to providing care for possible or actual coronavirus patients, but the lost revenue that the Provider Relief Fund payment covers must have been lost due to coronavirus. HHS encourages the use of funds to cover lost revenue so that providers can respond to the coronavirus public health emergency by maintaining healthcare delivery capacity, such as using Provider Relief Fund payments to cover:

All providers receiving Provider Relief Fund payments will be required to comply with the reporting requirements described in the Terms and Conditions and specified in future directions issued by the Secretary. HHS will provide guidance in the future about the type of documentation they expect recipients to submit on the CARES Act Provider Relief page https://www.hhs.gov/provider-relief/index.html.

 

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Information Released by MAHC on May 28, 2020:

 

As a follow-up to my previous notice (below) related to the State's PPE Reserves, Gloves (M, L, XL) and Gowns (Large only) are now available in addition to the previously reported Face Shields and Procedure Masks.

 

If you are in need of any of these items, complete the online PPE Request form by clicking here.

 

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Information Released by MAHC on May 19, 2020:

 

Face Shields & Procedure Masks Currently Available 

from State's PPE Reserves

 

PLEASE NOTE: MAHC has continually been advocating for home care and hospice to be a higher priority for PPE supplies. While the state's priority continues to remain with hospitals, EMS, and nursing homes, we have become aware that currently the State PPE Reserves warehouse has adequate supplies of Face Shields and Procedure Masks. If you are in need of these, I highly suggest you submit your order today. Click here to access the PPE Request form.

 

MAHC will now be receiving a daily list of what is available within the state's PPE reserves warehouse. We will notify members ASAP on the PPE items that are in adequate supply to include non-priority providers.

 

We were also just made aware that when a provider's PPE request has been denied, it will NOT be saved and reconsidered when the state receives adequate supplies. It was realized that they don't have the capability of retaining all the hundreds of orders that come in. They apologized for not making this more clear to us and providers.  Therefore, if you have submitted a request and received a denial, you will need to continue to send your requests in each time.

 

 

Also, please see information below related to the state's new PPE Webpage and options for Non-Profits to order supplies through Missouri Vocational Enterprises. 

 

New State PPE Webpage

In an effort to expand the PPE reserves and simplify the PPE process, the state has created a new COVID-19 webpage dedicated to be a one-stop shop for all information related to PPE. The PPE webpage will provide Missouri's latest information and resources in three categories including how to access PPE, guidance for use and optimization for maintaining your PPE supply for the duration of the COVID-19 epidemic.   

 

You can use this website to access the PPE marketplace, too.

 

Also, NEW to this website and to the state is the State PPE Reserves option. 

 

Missouri has limited PPE reserves to assist in filling these critical needs and will prioritize healthcare providers providing direct care to confirmed or suspected COVID patients. Note requests should only be submitted after all normal supply chains, including the Missouri COVID Supply Solution (aka Missouri PPE Marketplace), have been exhausted and you have a supply of fourteen days or less on hand as the quantities and types of PPE available through the state are limited.

Use this link https://survey123.arcgis.com/share/35c0d11050b04a809028d2caf9fd45fd?portalUrl=http://mophep.maps.arcgis.comto access the PPE Request Form. You will receive an automatically generated email notifying you of receipt of your request. Requests will be evaluated in the order in which they are received. If your request is approved, either in full or partially, you will receive an electronic notification upon shipment. If denied, you will receive an electronic verification of the decision.

 

PPE options for Non-profits and Governmental Entities

While many continue to struggle with obtaining PPE items, we wanted to make sure you are aware that not-for-profit entities may purchase items from Missouri Vocational Enterprises (MVE).  MVE operates through Missouri's Department of Corrections and produces and sells a number of items.  MVE may sell these items to any state agency, local government entities, or any not-for-profit agency. 

 

MVE has a variety of janitorial supplies, personal products (soap, toilet tissue, etc.), laundry supplies, and disinfectant supplies.  Most of these items can be found on the MVE website https://docservices.mo.gov/mve/products/consumables/consumable.html.

 

In addition, MVE has recently begun selling certain PPE items including cloth face coverings, isolation gowns, and hand sanitizer (gallon jugs).  PPE items are being prioritized to state agencies but may also be purchased by local government and not-for-profit entities as supplies are available. As with all PPE, some items are more readily available then others. These items can be found by clicking here or on their website at https://docservices.mo.gov/mve/index.html.

 

 

 

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Information Released by MAHC on May 8, 2020:

 

CMS Updates COVID-19 Home Health & Hospice Waivers

 

Late May 8, 2020 CMS updated its COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers document with welcome changes for home health agencies and hospices.  CMS expanded the types of therapists able to perform the initial and comprehensive assessment for all home health patients to include PTs and SLPs in addition to OTs for the duration of the PHE, regardless of whether or not the service establishes eligibility for the patient to be receiving home care.  CMS also expanded the waivers of the Life Safety Code pertaining to hospice inpatient units, specifically alcohol-based hand-rub dispensers, fire drills and temporary construction sections of the LSC. 

 

The updates are below.   


Home Health Agencies

Allow Occupational Therapists (OTs), Physical Therapists (PTs), and Speech Language Pathologists (SLPs)to Perform Initial and Comprehensive Assessment for all Patients (Revised since 4/30 Release)

CMS is waiving the requirements in 42 CFR §484.55(a)(2) and §484.55(b)(3)that rehabilitation skilled professionals may only perform the initial and comprehensive assessment when only therapy services are ordered. This temporary blanket modification allows any rehabilitation professional (OT, PT, or SLP)to perform the initial and comprehensive assessment for all patients receiving therapy services as part of the plan of care, to the extent permitted under state law, regardless of whether or not the service establishes eligibility for the patient to be receiving home care. The existing regulations at §5/8/2020191484.55(a) and (b)(2) would continue to apply; rehabilitation skilled professionals would not be permitted to perform assessments in nursing only cases. We would continue to expect HHAs to match the appropriate discipline that performs the assessment to the needs of the patient to the greatest extent possible. Therapists must act within their state scope of practice laws when performing initial and comprehensive assessments and access a registered nurse or other professional to complete sections of the assessment that are beyond their scope of practice. Expanding the category of therapists who may perform initial and comprehensive assessments provides HHAs with additional flexibility that may decrease patient wait times for the initiation of home health services.

 

Hospice Inpatient Units

Multiple Providers: Specific Life Safety Code (LSC) Waiver Information: (New since 4/30 Release)

CMS is waiving and modifying particular waivers under 42 CFR §482.41(b) for hospitals; §485.623(c) for CAHs; §418.110(d) for inpatient hospice; §483.470(j) for ICF/IIDs and §483.90(a) for SNF/NFs. Specifically, CMS is modifying these requirements as follows:

 

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Information Released by MAHC on May 8, 2020:

 

Please find attached information related to the following:

Click here to download today's information.

 

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Information Released by MAHC on May 7, 2020:

 

Good News Related to CARES Act Funding for Home Health & Hospice

 

 

Clarification on CARES Act Distributions, Potential Fund Takebacks
(from NAHC)

 

NAHC has become aware of concerns about a "take-back" of monies related to the Emergency Fund distribution that occurred on April 10 and April 17, with the second distribution that began on April 24. The amount distributed in the first round turned out to be greater than the calculated amount set out in the second round of funds distribution, and some are concerned there will be an effort to recover some of that money.

 

The first distribution was based on a provider's 2019 fee for service Medicare claims data and providers received approximately 6.2 percent of that amount, with an intended total of $30 billion across the whole Medicare program. The second distribution is based on two percent of the providers "net patient revenue" for 2018, with cost reports and other documentation is being used for that distribution. The Department of Health and Human Services issued a calculation formula based on $2.5 trillion in overall spending with a fund payment of two percent of that amount for purposes of distributing both the initial $30 billion and an additional $20 billion. As that formula combined the two distributions, the question surfaced as to whether some providers would need to give money back if the first distribution exceeded the amount calculated through the second formula.

 

NAHC data shows that nearly 85 percent of home health agencies (HHA) and virtually all hospices would potentially be in a take-back position as the proportion of fee for services revenues exceeded 32.25 percent of the total revenues, the point when the first distribution calculation would be greater than the second distribution calculation. 

 

After more than a week of confusion and anxiety, NAHC had the opportunity to raise the issue earlier this week with Department of Health and Human Services (HHS) Deputy Secretary Eric Hargan and his team. Hargan confirmed that HHS does not intend to take back any of the funds from the first distribution based on the calculation determined under the second formula. Instead, any take-back would be limited to a later reconciliation based on a provider's use of the money.

 

The fund is available to help offset the loss of provider revenue due to devastation caused by the COVID-19 pandemic.

 

In our conversation, an example was presented of a home health agency with $20 million in overall net patient revenue and $10 million in Medicare fee for service revenue. With the first distribution, that HHA would have received approximately $620,000.  With the second formula to distribute the additional $20 billion, the overall distribution would be calculated at $400,000. That means the HHA would not receive any distribution from the second round as it was less than was already issued to the provider. Hargan confirmed that the HHA would not need to return the $220,000 difference. The full $620,000 would be subject though to a later determination as to whether the funds were fully used on Covid-19 costs and lost revenue.

 

Providers are required to file quarterly reports on such. NAHC's Home Care and Hospice Financial Managers Association (HFMA) Workgroup has developed a documentation template for securing that data. Click on the following to access the documentation template for securing that data:  COVID-19 Relief Funding Revenue and Cost Tracking Tool)

 

Hargan further indicated that the "overpayment " reference in the attestation portal for the fund is meant to address situations where the provider knows that the fund distribution calculation is in error. For example, if the amount tendered does not conform to the provider's 2019 fee for service claim revenue or the overall net patient revenue from 2018.  It is intended to address errors in those data inputs.

 

Updated Provider Relief Fund FAQs 

HHS has updated and released several new FAQs (indicated by, "Added 5/6/2020"), including related to the terms and conditions as well as recoupment. 

 

Of note:

What should a provider do if a General Distribution payment is greater than expected or received in error? (Added 5/6/2020)
Providers that have been allocated a payment must sign an attestation confirming receipt of the funds and agree to the Terms and Conditions within 30 days of payment. Generally, if a provider does not have or anticipate having COVID-related lost revenues or increased expenses equal to or in excess of the relief payments received, they should return the funds. If a provider believes it was overpaid or may have received a payment in error, it should reject the entire General Distribution payment and submit the appropriate revenue documents through the General Distribution portal to facilitate HHS determining their correct payment. If a provider believes they are underpaid, they should accept the payment and submit their revenues in the provider portal to determine their correct payment.

Does HHS intend to recoup any payments made to providers not tied to specific claims for reimbursement, such as the General Distribution payments? (Added 5/6/2020)
The Provider Relief Fund and the Terms and Conditions require that recipients be able to demonstrate that lost revenues and increased expenses attributable to COVID-19, excluding expenses and losses that have been reimbursed from other sources or that other sources are obligated to reimburse, do not exceed total payments from the Relief Fund. Generally, HHS does not intend to recoup funds as long as a provider's lost revenue and increased expenses exceed the amount of Provider Relief funding a provider has received. HHS reserves the right to audit Relief Fund recipients in the future to ensure that this requirement is met and collect any Relief Fund amounts that were made in error or exceed lost revenue or increased expenses due to COVID-19. Failure to comply with other Terms and Conditions may also be grounds for recoupment.

 

Click here to access the updated FAQs.



HHS Extends Deadline for Attestation, Acceptance of Terms and Conditions for Provider Relief Fund Payments to 45 Days

The Department of Health and Human Services has extended the deadline for healthcare providers to attest to receipt of payments from the Provider Relief Fund and accept the Terms and Conditions. Providers will now have 45 days, increased from 30 days, from the date they receive a payment to attest and accept the Terms and Conditions or return the funds. As an example, the initial 30-day deadline for providers who received payment on April 10, 2020, is extended to May 24 from May 9, 2020. With the extension, not returning the payment within 45 days of receipt of payment will be viewed as acceptance of the Terms and Conditions.

 

President Trump is providing support to healthcare providers fighting the COVID-19 pandemic through the bipartisan CARES Act and Paycheck Protection Program and Health Care Enhancement Act which provide $175 billion in relief funds to hospitals and other healthcare providers on the front lines of the coronavirus response. This funding will be used to support healthcare-related expenses or lost revenue attributable to COVID-19 and to ensure uninsured Americans can get treatment for COVID-19.

In allocating the funds, the Administration is working, among other things, to address both the economic harm across the entire healthcare system due to the stoppage of elective procedures, and addressing the economic impact on providers particularly impacted by COVID-19, and to do so as quickly and transparently as possible.

Visit hhs.gov/providerrelief for more information on the allocations. Recipients of payments from any of these allocations must attest and accept the Terms and Conditions within 45 days.

 

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Information Released by MAHC on May 1, 2020:

 

Please find information related to the following:

  Click here to download today's information.

 

Click here for detailed information related to the newly released waivers and the Interim Final Rule with Comment (IFC).

 

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Information Released by MAHC on April 27, 2020:

 

Please find attached information related to the following:

  Click here to download today's information.

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Information Released by MAHC on April 22, 2020:

 

PPE/Missouri COVID Supply Solution                    

 

The State of Missouri continues to work across multiple channels to improve access to personal protective equipment (PPE) for healthcare providers.  It is important for health care providers to realize that PPE supply chains will be affected for a long time and as more health care providers and other businesses resume activities, the access to supplies of PPE will continue to be stretched.  Understanding the PPE needs of healthcare providers and accessing PPE continues to be a challenge. 

 

The State of Missouri has been actively engaged in outreach to businesses in an effort to open up new supply chains for PPE and other critical medical supplies. In an effort to streamline this process, we are very excited to announce the Missouri COVID Supply Solution is live and ready for your use. This application is designed to match health care providers to suppliers of PPE and other medical supplies.

 

To participate, please go to the Missouri COVID Supply Solution to register as a health care provider using Edge, Chrome, Firefox, or Opera as your internet browser. Once your registration is complete, you can immediately begin adding your current PPE inventory and amounts you want to purchase. Once you complete this step, you can begin searching PPE suppliers. In order for the state to understand demand for PPE supplies, please update your PPE inventory amounts every three days within the solution.  

 

Thank you for your participation in the Missouri COVID Supply Solution.  This is another tool for providers to gain access to needed PPE. Please note, the state is attempting to ensure that the manufacturers and suppliers of PPE identified in this solution are valid.  Purchasers should be aware and make sound purchasing decisions.  Health care providers should continue to work through the regular supply chain to access PPE, also.    

 

Any questions regarding this information should be directed to Long Term Services and Supports via email at ltss@health.mo.gov.

 

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Information Released by MAHC on April 20, 2020:

 

Please find information related to the following:

MO HealthNet Recent Hot Tips

MO HealthNet recently released the following Hot Tips in relation to regulatory relief/waivers effective March 13, 2020 until the end of the public health emergency.

Home Health:

Click here to access the Home Health MO HealthNet Hot Tip.

Healthy Children and Youth (HCY) Personal Care: for questions regarding processes and services authorized by the DHSS/Division of Community and Public Health (DCPH)/Special Health Care Needs (SHCN), contact the appropriate Regional Office

Click here to access the HCY MO HealthNet Hot Tip.

 

4-16-20 UPDATED COVID-19 Emergency Guidance Released for HCBS Providers

 

The COVID-19 Emergency Guidance has been updated again.  Providers should review all sections identified as new or updated for the latest guidelines.

 

Click on the following link to access the HCBS Provider Information Page that includes the UPDATED Emergency Guidance: https://health.mo.gov/seniors/hcbs/covid-19-provider-info.php or click here for a PDF version.

 

Updated Sections:

Updated Provider Resources:

A memorandum has also been added at the following link:  

https://health.mo.gov/seniors/hcbs/infomemos.php. 

Please see INFO 04-20-02 COVID-19 Guidance - Personal Care Provider Respite Authorization for Adult Day Care (ADC) Participants.

Please continue to check the DHSS COVID-19 Page for any evolving guidance from DHSS or CDC regarding PPE and transmission precautions.


Any questions regarding the guidance or memorandum should be directed to Long Term Services and Supports via email at LTSS@health.mo.gov

 

 

DHSS Issues Health Guidance - Return to Work Messaging

On April 17, the Department of Health and Senior Services released the following Health Guidance: COVID-19 and Return to Work Messaging - Expanded Guidance for Critical Infrastructure Personnel Involved in the Provision of Direct Client Care.

Click here to read the Guidance.

 

CMS Issues Recommendations to Re-Open Health Care Systems in Areas with Low Incidence of COVID-19

Yesterday, April 19, the Centers for Medicare & Medicaid Services issued new recommendations specifically targeted to communities that are in Phase 1 of the Guidelines for President Trump's Opening Up America Again with low incidence or relatively low and stable incidence of COVID-19 cases. The recommendations update earlier guidance provided by CMS on limiting non-essential surgeries and medical procedures. The new CMS guidelines recommend a gradual transition and encourage health care providers to coordinate with local and state public health officials, and to review the availability of personal protective equipment (PPE) and other supplies, workforce availability, facility readiness, and testing capacity when making the decision to re-start or increase in-person care.

 

Click here to find the new recommendations.

Click here to find the Guidelines for Opening Up America Again.

 

Trump Administration Announces New Nursing Homes COVID-19 Transparency Effort  


On April 19, under the leadership of President Trump, the Centers for Medicare & Medicaid Services (CMS) announced new regulatory requirements that will require nursing homes to inform residents, their families and representatives of COVID-19 cases in their facilities. In addition, as part of President Trump's Opening Up America, CMS will now require nursing homes to report cases of COVID-19 directly to the Centers for Disease Control and Prevention (CDC). This information must be reported in accordance with existing privacy regulations and statute. This measure augments longstanding requirements for reporting infectious disease to State and local health departments. Finally, CMS will also require nursing homes to fully cooperate with CDC surveillance efforts around COVID-19 spread.


Click here to read the QSO-20-26-NH Guidance.

 

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Information Released by MAHC on April 17, 2020:

 

Please see additional follow-up information from MAHC's legal firm, Husch Blackwell related to Medicare provider relief payments:

HHS Updates Guidance on Provider Relief Payments

April 16, 2020

 

On Friday April 10, 2020, the US Department of Health & Human Services (HHS) began

distributing $30 billion in grants to healthcare providers as part of the $100 billion in relief included in the CARES Act. As discussed in our previous post, Best Practices Related to Public Health and Social Services Emergency Fund Payments, the Relief Fund payments, while welcome, come with a series of Terms and Conditions requiring provider attestation that are vague and raise a series of questions that will necessitate additional guidance from HHS.

 

Specifically, the Terms and Conditions create many questions about, for example, whether providers who are not actively treating COVID-19 patients may keep the Relief Fund payments, and, if they can, on what those Relief Fund payments may be spent. But when interpreting these Terms and Conditions, we keep in mind that HHS indicated on its website that it will interpret broadly what patients are "possible cases of COVID-19."

 

Terms and Conditions updated by HHS

On April 7, the Centers for Medicare & Medicaid Services Administrator, Seema Verma, when addressing the Relief Fund payments, said "There are no strings attached, so the healthcare providers that are receiving these dollars can essentially spend that in any way that they see fit." Yet the Term and Conditions attached to the Relief Fund payments, on their face, lack that flexibility. Instead they state, among other things, that the recipient must certify it currently provides diagnoses, testing or care for individuals with possible or actual cases of COVID-19; that the payment will only be used to prevent, prepare for and respond to coronavirus; and shall reimburse the recipient only for health care-related expenses or lost revenues attributable to coronavirus. The Terms and Conditions do not define, for example, who is a "possible" case of COVID-19.

 

Yet HHS says it will interpret at least some aspects of the Terms and Conditions broadly.

Specifically, this week HHS updated the Terms and Conditionsto remove the "currently" language. Instead, the Terms and Conditions now allow providers who deliver or delivered after January 31, 2020, diagnoses, testing or care for individuals with possible or actual cases of COVID-19 to accept these funds. Additionally, on its website, specifically the Provider Relief page, HHS explains that, in order to be eligible for the funds: "Care does not have to be specific to treating COVID-19. HHS broadly views every patient as a possible case of COVID-19."

 

The Attestation Portal now open

As discussed in our previous post, all providers will be required to sign an attestation

confirming receipt of the funds and agreeing to the Terms and Conditions of payment.

Importantly, on its Provider Relief page, HHS recently clarified that not returning the funds within 30 days will be viewed as acceptance of the Terms and Conditions. Today, April 16, 2020, HHS opened the Attestation Portal. If a provider chooses to return the funds, if must follow the steps on the Attestation Portal.

 

We anticipate further guidance regarding the use of these funds and Husch Blackwell will be tracking this issue closely for our clients.

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Information Released by MAHC on April 15, 2020:

 

Please find information related to the following:

 

Actions Practitioners Can Take to Prevent Spread of COVID-19

All home care agencies and staff are trying to stay safe while providing care to patients and families in the home. The National Association of Home Care & Hospice (NAHC) teamed up with Mary McGoldrick MS, RN, CRNI, to share her expertise and to answer real-time, exact questions about the best ways to prevent the spread of COVID-19.

 CLICK HERE for detailed ANSWERS related to the following:

Click on the following links for Mary's March 27th webinar recording and handouts:

Handouts

Recording

 

Procedural Mask Use - Important Points from Mary McGoldrick

 

On April 13, the CDC updated its information related to masking (and more). Click here to access the details.

 

For now, here's what is important for your staff to know right now about masking:

Remember that with each contact with a face mask or respirator (i.e., taking it off or putting it back on, or even touching it by mistake), it increases the staff's risk for self-contamination (and thus the preference for extended use versus re-use).

 

 

DHSS Interim Recommendations for PPE Sterilization, Re-use and Extended Use

 

The Department of Health and Senior Services released Interim Recommendations for PPE Sterilization, Re-use and Extended Use.

Click here to read the April 10th Interim Recommendations.

 

 

DHSS COVID-19 Issues Update - Interim Case Definition and Reporting Information for Healthcare Providers

 

The Department of Health and Senior Services released an update to their April 6th Update - Reporting COVID-19 Cases. 

 

Click hereto read the April 10th Update - COVID-19 Interim Case Definition and Reporting Information for Healthcare Providers.

 

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Risk From "Easy" Money - Husch Blackwell Advisory Available for MAHC Home Health & Hospice Members

 

As a follow-up from yesterday (below), as promised, please find the Husch Blackwell Advisory on the Risks of Spending Public Health and Social Services Emergency Fund Payments.

Click here to view the Advisory.

 

 

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Information Released by MAHC on April 14, 2020:

 

Below is information the Division of Senior & Disability Services (DSDS) released from April 7, 9 and 10.

 

Also, if you missed our April 10 webinar - COVID-19: Current Guidance, Information & Questions - for In-Home and Consumer Directed Services Medicaid personal care providers, click on the following links for the webinar recording and handouts.

 

Webinar Recording
Handout 1

Handout 2

 

Combined - UPDATED COVID-19 Emergency Guidance
Released for HCBS Providers

 

The COVID-19 Emergency Guidance has been updated again.  Providers should review all sections identified as new or updated for the latest guidelines.

 

Click on the following link to access the HCBS Provider Information Page that includes all of the UPDATED Emergency Guidance: https://health.mo.gov/seniors/hcbs/covid-19-provider-info.php or click here for a PDF version.

 

April 7

Updated Sections:

This section was updated to add clarification to the guidance released early this morning related to the flexibility of family member hiring.  Please note, this guidance only pertains to agency-model. 

 

April 9
A new resource titled "DHSS Exposure Worker Guidance" was added under the Provider Resources tab.  The resource provides interim guidance for implementing safety practices for critical infrastructure workers who may have had exposure to a person with suspected or confirmed COVID-19

Additionally, a disclaimer was added to the Policy Clarification Questions (PCQs) explaining guidance released during the COVID-19 emergency period supersedes any conflicting information found within the PCQs

The PCQs may be accessed at the following link: https://health.mo.gov/seniors/hcbs/pdf/pcq.pdf

 

April 10

A memorandum was issued regarding COVID-19 Medicaid eligibility guidance.

 

Please refer to INFO 04-20-01 at the link provided below.

https://health.mo.gov/seniors/hcbs/infomemos.php   


Additionally, the COVID -19 Emergency Guidance has been updated:


Updated Sections:

Any questions regarding the guidance or memorandums should be directed to Long Term Services and Supports via email at LTSS@health.mo.gov

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Additional Valuable MAHC Member COVID-19 Resources Available

Please find below additional COVID-19 resources related to employment issues, home health waiver FAQs and best practices for monies Medicare FFS providers received from the CARES Act Relief Fund.

FAQ for Employment Issues During COVID-19 Pandemic
 Click here for this invaluable resource that answers your questions about how the COVID-19 pandemic has changed employment issues in the home care industry. It has important news updates on the Families First Coronavirus Response Act, the CARES Act, employee relations, and more.


Home Health Waiver's - FAQ's

From recent provider calls with CMS, NAHC has completed three sets of frequently asked questions and answers (FAQs) on the topics of:

Click on each link view the FAQs.

 

Best Practices Related to Public Health and Social Services Emergency Fund Payments


MAHC's legal firm, Husch Blackwell has prepared a best practices resource for MAHC members regarding the terms and conditions relating to the federal monies home health and hospice providers received on Friday.  Click here to view the resource. 

 

Also, Husch Blackwell will be developing a detailed risk advisory that contains greater detail about the various laws and regulations governing the retention and expenditure of the funds. MAHC will send out to members once we receive.

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Information Released by MAHC on April 10, 2020:

 

CARES Act Provider Relief $100 Billion Emergency Fund - Immediate Infusion of $30 Billion into Healthcare System to Medicare FFS Providers

 

CMS plans to begin the release of $30 billion of the emergency funds starting today. Below is the basic framework. Both home health agencies and hospices will receive payments. The exact timing as to the distribution is not known at this point, although some entities should receive electronic payments as early as today.

 

Links to the announcement:

 

CARES Act Provider Relief Fund

President Trump is providing support to healthcare providers fighting the COVID-19 pandemic. On March 27, 2020, the President signed the bipartisan CARES legislation that provides $100 billion in relief funds to hospitals and other healthcare providers on the front lines of the coronavirus response. This funding will be used to support healthcare-related expenses or lost revenue attributable to COVID-19 and to ensure uninsured Americans can get testing and treatment for COVID-19.

 

Immediate infusion of $30 billion into healthcare system

Recognizing the importance of delivering funds in a fast and transparent manner, $30 billion is being distributed immediately - with payments arriving via direct deposit beginning April 10, 2020 - to eligible providers throughout the American healthcare system. These are payments, not loans, to healthcare providers, and will not need to be repaid.

 

Who is eligible for initial $30 billion

 

How are payment distributions determined

 

What to do if you are an eligible provider

 

Is this different than the CMS Accelerated and Advance Payment Program?

Yes. The CMS Accelerated and Advance Payment Program has delivered billions of dollars to healthcare providers to help ensure providers and suppliers have the resources needed to combat the pandemic. The CMS accelerated and advance payments are a loan that providers must pay back. For more information from CMS, click here.

 

How this applies to different types of providers

All relief payments are being made to providers and according to their tax identification number (TIN).

 

For example:

 Priorities for the remaining $70 billion

The Administration is working rapidly on targeted distributions that will focus on providers in areas particularly impacted by the COVID-19 outbreak, rural providers, providers of services with lower shares of Medicare reimbursement or who predominantly serve the Medicaid population, and providers requesting reimbursement for the treatment of uninsured Americans.

 

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Additional MO and CMS Waivers Approved for Home Health & Hospice

 

 

MO Approves Waivers to Allow Nurse Practitioners and Physician Assistants to Order Home Health Services and Act as Attending Physicians Under Hospice

 

The Governor's office has approved MAHC's waiver requests allowing advance practice registered nurses and physician assistants to order home health services and act as the attending physician for hospice services during this COVID-19 pandemic crisis.  

 

Advanced Practice Registered Nurses and Physician Assistants

Section 197.400(3), RSMo, and 19 CSR 30-26.010(1)(A) shall be waived to the extent that the provisions require only a physician to order home health services at the residence of patients, including writing and signing a plan of treatment for these patients. This waiver shall allow advanced practice registered nurses and physician assistants to also be able to order home health services at the residence of patients, including writing and signing a plan of treatment for these patients.

 

Section 19 CSR 30-35.010(1)(A)1 shall be waived to the extent the provisions define "attending physician" to be only a person licensed as a doctor of medicine or osteopathy in this state or a bordering state throughout 19 CSR 30-35.010. This waiver shall allow advanced practice registered nurses and physician assistants to also be attending physicians and complete the requirements of an attending physician in 19 CSR 30-35.010.

 

Click here to view the signed waivers.

 

CMS Releases Additional Waivers for Home Health & Hospice

 

Home Health

Allow occupational therapists (OTs) to perform initial and comprehensive assessment for all patients. 42 C.F.R. 484.55(a)(2) and 484.55(b)(3). CMS is waiving the requirement that OTs may only perform the initial and comprehensive assessment if occupational therapy is the service that establishes eligibility for the patient to be receiving home health care. This temporary blanket modification allows OTs to perform the initial and comprehensive assessment for all patients receiving therapy services as part of the plan of care, to the extent permitted under state law, regardless of whether occupational therapy is the service that establishes eligibility. The existing regulations at § 484.55(a) and (b)(2) would continue to apply that OTs and other therapists would not be permitted to perform assessments in nursing only cases. We would continue to expect HHAs to match the appropriate discipline that performs the assessment to the needs of the patient to the greatest extent possible. Therapists must act within their state scope of practice laws when performing initial and comprehensive assessments, and access a registered nurse or other professional to complete sections of the assessment that are beyond their scope of practice. Expanding the category of therapists who may perform initial and comprehensive assessments to include OTs provides HHAs with additional flexibility that may decrease patient wait times for the initiation of home health services.

 

Hospice

Hospice aide competency testing allow use of pseudo patients.
42 C.F.R. 418.76(c)(1). CMS is temporarily modifying the requirement in § 418.76(c)(1) that a hospice aide must be evaluated by observing an aide's performance of certain tasks with a patient. This modification allows hospices to utilize pseudo patients such as a person trained to participate in a role-play situation or a computer-based mannequin device, instead of actual patients, in the competency testing of hospice aides for those tasks that must be observed being performed on a patient. This increases the speed of performing competency testing and allows new aides to begin serving patients more quickly without affecting patient health and safety during the public health emergency (PHE).

 

12-hour annual in-service training requirement for hospice aides.
42 C.F.R. 418.76(d). CMS is waiving the requirement that hospices must assure that each hospice aide receives 12 hours of in-service training in a 12-month period. This allows aides and the registered nurses (RNs) who teach in-service training to spend more time delivering direct patient care.

 

Click here to view the updated waivers.

 

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 Information Released by MAHC on April 7, 2020:

 

Below is the notice from DSDS related to the most recent updated HCBS COVID-19 Emergency Guidance.

 

Please note one BIG change under Caregiver Requirements section. This is a change from what DSDS previously thought would be easily approved by CMS. Unfortunately, CMS did not approve the allowance of family members living in the same household to qualify for the waiver. 

Eligible Caregivers (UPDATED 4/06/20)

Family members (spouse and legal guardian excluded) may be eligible to be hired as an aide to provide care. Family members (absent the exceptions above) will only be allowed to provide services if he/she does not reside in the same residence, and he/she will only be allowed to provide services if no other caregiver is available. Family Care Safety Registry (FCSR) filing is still required (see below for further guidance).

 

Also, MAHC will be hosting a webinar on Friday, April 10 from 9:00-10:00 am related to the In-Home and CDS COVID-19 Emergency Guidance.  The webinar will be presented by DSDS Director, Jessica Bax and MMAC Director, Dale Carr.  Also in addition to Directors' Bax and Carr, DSDS' LTSS management team will be on hand to answer all your questions.  Be watching for registration information coming soon!  This will be your opportunity to hear directly from the experts and one of the most informative webinars available.

 

 

4-6-20 UPDATED COVID-19 Emergency Guidance
Released for HCBS Providers

 

The COVID-19 Emergency Guidance has been updated again.  Providers should review all sections identified as new or updated for the latest guidelines.

 

Click on the following link to access the HCBS Provider Information Page that includes the UPDATED Emergency Guidance: https://health.mo.gov/seniors/hcbs/covid-19-provider-info.php or click here for a PDF version.

 

Updated Sections:

These sections have been updated to clarify which family members may provide services and in what circumstances.  Please read carefully as this information may impact your current hiring decisions.

 

The Provider Resources tab has also been updated.  Please review the following updates:

New Resources:

Updated Resources:


Any questions regarding the guidance or memorandum should be directed to Long Term Services and Supports via email at LTSS@health.mo.gov

 

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Information Released by MAHC on April 6, 2020:

 

Multiple Guidance & Resources on N-95 Masks and Other PPE

 

In this ever changing, always updating world of COVID-19 that we all now live in, below is a variety of recent guidance (some updated) and various additional resources related to PPE.

 

 

Use of Cloth Face Coverings to Help Slow the Spread of COVID-19

The CDS is now recommending wearing cloth face coverings in public settings where other social distancing measures are difficult to maintain (e.g. grocery stores and pharmacies), especially in areas of significant community-based transmissions. Click here to read the CDC guidance.

 


Various Guidance Related to Reuse of N-95 Masks

Below are recommendations from hospital epidemiologists and the CDC regarding reuse of N-95 masks:

 

Strategies for Optimizing the Supply of Facemasks
In addition to the mask reuse guidance, the CDC also issued strategies for optimizing the supply of masks. Many are already employing these strategies.
https://www.cdc.gov/coronavirus/2019-ncov/hcp/ppe-strategy/face-masks.html


CDC Issues Guidance on Decontamination and Reuse of Filtering Facepiece Respirators
On March 31, the Centers for Disease Control and Prevention (CDC) issued guidance to health care professionals on Decontamination and Reuse of Filtering Facepiece Respirators using Contingency and Crisis Capacity Strategies. While disposable filtering facepiece respirators are not approved for routine decontamination and reuse as a standard of care, such action may be necessary as a crisis capacity strategy. This guidance discusses crisis standards of care for such decontamination and information regarding various methods for decontamination.


FAQs on Shortages of Surgical Masks and Gowns
Click here to access the U.S. Food and Drug Administration (FDA) frequently asked questions on shortages of surgical masks and gowns.

  

 

FDA Issues New Guidance Related to PPE

The following is provided by MAHC's legal firm, Husch Blackwell -

 

We are updating you on the latest guidance from the U.S. Food and Drug Administration (FDA) regarding personal protective equipment, including masks, respirators, face shields, gowns and gloves.  FDA just issued two new guidance documents:  "Enforcement Policy for Face Masks and Respirators During the Coronavirus Disease (COVID-19) Public Health Emergency (Revised)" and "Enforcement Policy for Gowns, Other Apparel, and Gloves During the Coronavirus Disease (COVID-19) Public Health Emergency."  Click on the following links to access the new guidance documents:

These new guidance documents significantly reduce the regulatory requirements that apply to most personal protective equipment.  Specifically, the following requirements are temporarily suspended: 

 In their place, FDA provides criteria for when "such devices would not create such an undue risk" based on the type of device.  Many of the requirements relate to appropriate labeling and claims for the product based on its type.  For select devices, this includes "a general statement about devices that have not been cleared by FDA and recommendations against use when FDA-cleared [devices] are available."  The key technical requirements for masks, respirators and surgical gowns are flammability and fluid resistance testing (where liquid barrier performance is asserted).  The key technical requirement for surgeon's gloves is meeting the requirements of ASTM D3577: Standard Specification for Rubber Surgical Gloves.

 

The guidance for face masks and respirators also provides information on what type of information FDA would like to receive in an Emergency Use Authorization (EUA) for those devices, including EUAs covering the decontamination of previously cleared, single-use face masks and respirators and EUAs for face masks and respirators that have not been previously cleared by FDA. Given the guidance, submitting an EUA appears to be advisory (i.e., recommended but not required).  Submitting one would likely help secure Public Readiness and Emergency Preparedness Act (PREP Act) immunity, however.

 

CDC - PPE Burn Rate Calculator
The Personal Protective Equipment (PPE) Burn Rate Calculator excel icon[XLS - 39 KB] is a spreadsheet-based model that provides information for healthcare facilities to plan and optimize the use of PPE for response to coronavirus disease 2019 (COVID-19). Similarly, non-healthcare facilities (e.g., correctional facilities) may find this tool useful for planning and optimizing PPE use as part of the response to COVID-19. This tool can also be used for planning PPE use outside the context of COVID-19, where PPE shortages may also occur due to supply chain issues related to the COVID-19 response (e.g. manufacturing facilities).

 

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Personal Protective Equipment - PPE a Priority for MAHC

Potential Resources Available

 

The Missouri Alliance for Home Care (MAHC) continues to make PPE a priority for all home care providers. We constantly ask our state leaders to grant priority status to all home care service providers during the COVID-19 outbreak. Our message is simple - priority access will enable home care providers to continue caring for elderly and disabled safely in the home and keep caregivers on the front-line safe from exposure and minimize the risk of community spread.

 

MAHC has provided estimated PPE needs to DHSS, MO HealthNet, the Administration, legislators, etc. I have even had local Alderman reach out to me for help with their local provider needs. Please know that one of our main priorities is to continue to advocate for home care providers to obtain PPE. As you all know, the shortage continues to be an issue and we hope that in the days/weeks to come, this will be addressed.

 

In the meantime, we want to provide you with as much information and options as possible.

 

MAHC, as I am sure all of you are experiencing, is contacted daily by PPE vendors. MAHC does not have the resources to vet all these sources. The last thing we want to do is put our members at risk and provide information that has not been properly screened.

 

However, I have been contacted related to three potential sources that have had a little more "vetting" behind them. One is a vendor currently used by a MAHC member and the other two are a recommendation from a well-known and reputable lobby firm here in Jefferson City (Flotron & McIntosh). Below is information on the three companies.

 

While MAHC cannot and is not endorsing these, I wanted to pass along the information as a possible resource for your PPE needs. If you choose to order from any of these companies or if you have reputable sources for PPE that you would like to share your experience with fellow providers, please send the information to me to share as we are all in this together.

 

Two PPE Sources (info provided by Flotron & McIntosh)

Questions related to either company can also be directed to:
John askin, Flotron & McIntosh
John@govconsultants.com
314-33-7410G

81 Logistics is owned by National Pro Football Hall of famer Tim Brown. Tim and his team are based out of Dallas, Texas. Their company specializes in international and national distribution and logistics. The Company's website link is https://81logisticsgroup.com/

All of their products have certifications that can be provided prior to purchase. Shipping time ranges from 7 days up to 20 days for completion. The full balance for orders are due when the order is placed. The company can obtain N95 Masks, Hand sanitizer, swabs, surgical gowns, and a host of other vital PPE. The company is a DBE MBE Business.  Click here to see their PPE catalog.

 

KDK is a logistics company based out of St. Louis. Currently, KDK is able to obtain PPE equipment and other medical supplies from various international manufacturers. Delivery for supplies start within 7 days. When placing an order, 50% is due up front and the remaining balance is due at the time of shipping. References for this company can be provided. Certifications for the products are also attached.

Click here to see the KDK Product Pricing Guide.

 


Source currently used by a MAHC member (member stated their ordering and delivery process was very smooth)

Philippe Gabay, Vice President of Business Development for Radiant Global Logistics is working with states on supplying them with PPE as well as the private sector.

Click here to see Radiant's mask pricing list
Click here to see Radiant's medical supply pricing list

Contact Info:

Philippe Gabay
Vice President of Business Development

Main:    +1.610.586.5050

Mobile:  +1.215.298.1600
Fax:      +1.610.586.5511

Email:    pgabay@radiantdelivers.com

Website: www.radiantdelivers.com

Radiant Global Logistics, Inc. * 514 Kaiser Drive * Folcroft, PA 19032 *

 

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Additional Private Duty Nursing (PDN) Services

COVID-19 Flexibilities Announced

 

We are pleased to announce that MO HealthNet released additional flexibilities for PDN providers (previous flexibilities announced in my March 17 notice below). These additional measures along with the March 17 notice were issues MAHC had previously worked with MO HealthNet on related to getting permanent changes to the regulations. We are thankful that MO HealthNet is implementing these additional items during the emergency period. We will continue to work with MO HealthNet through the normal regulation process on a permanent change.

 

MO HealthNet - Provider Hot Tip - April 02, 2020

The MO HealthNet Division (MHD) is responding to an outbreak of respiratory disease caused by a novel (new) coronavirus. The virus has been named "SARS-CoV-2" and the disease it causes has been named "coronavirus disease 2019" (abbreviated "COVID-19").

 

In addition to the changes indicated in the MO HealthNet Private Duty Nursing Services Bulletin Volume 42, No. 32 dated March 17, 2020, effective immediately and until the end of the public health emergency due to COVID-19, the following additional changes are implemented for private duty nursing services:

 

Assistant Nursing Supervisor
An LPN with three (3) years' experience may act as the assistant supervisor under the RN supervisor. One (1) year of experience must be in high acuity pediatric nursing care in a hospital, home care agency or residential setting. The assistant nursing supervisor may be responsible for case conferences with staff nurses, documenting the conferences, developing plan of care after the initial plan of care has been established by an RN, training and evaluation of direct care staff and other duties delegated by the Nursing Supervisor.

 

TB Testing
Centers for Disease Control guidelines regarding tuberculosis (TB) screening, testing, treatment and education are to be followed. (The current requirement is to perform annual TB testing.)

 

Click here to access MO HealthNet's "Provider Hot Tip" page.

 

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March 17, 2020 (notice to MAHC members)

 

Private Duty Nursing (PDN) Services - COVID-19 Changes

 

MAHC is working diligently to advocate for waivers and other measures to assist all providers during this challenging time. Today, MO HealthNet released a bulletin that includes changes to Private Duty Nursing (PDN) services processes due to the ongoing COVID-19 outbreak.

 

Click here to access the memo.

 

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Information Released by MAHC on April 3, 2020:

 

MAHC continues to have daily conversations with the Division of Senior and Disability Services related to the COVID-19 Emergency Guidance.  Based on these conversations, the guidance continues to be updated to make sure HCBS providers get the clarification they need.  Please continue to send me your questions related to this guidance as we all work together to allow you to continue serving our most vulnerable.

 

4-3-20 UPDATED COVID-19 Emergency Guidance
Released for HCBS Providers

 

The COVID-19 Emergency Guidance has been updated again.  Providers should review all sections identified as new or updated for the latest guidelines.

 

Click on the following link to access the HCBS Provider Information Page that includes the UPDATED Emergency Guidance: https://health.mo.gov/seniors/hcbs/covid-19-provider-info.php or click here for a PDF version.

 

Updated Sections:


INFO-03-20-04 - https://health.mo.gov/seniors/hcbs/infomemos.php

 

Any questions regarding the guidance or memorandum should be directed to Long Term Services and Supports via email at LTSS@health.mo.gov

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Information Released by MAHC on April 2, 2020:

 

MAHC continues to have daily conversations with the Division of Senior and Disability Services related to the COVID-19 Emergency Guidance.  Based on these conversations, the guidance continues to be updated to make sure HCBS providers get the clarification they need.  Please continue to send me your questions related to this guidance as we all work together to allow you to continue serving our most vulnerable.

 

4-2-20 UPDATED COVID-19 Emergency Guidance

Released for HCBS Providers

 

The COVID-19 Emergency Guidance has been updated again.  Providers should review all sections identified as new or updated for the latest guidelines.

 

Click on the following link to access the HCBS Provider Information Page that includes the UPDATED Emergency Guidance: https://health.mo.gov/seniors/hcbs/covid-19-provider-info.php  or click here for a PDF version.

 

Updated Sections:

New Sections:

 

Any questions regarding this information should be directed to Long Term Services and Supports via email at ltss@health.mo.gov.

 

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Annette Lee, Provider Insights, Shares Informal Look 

at Home Health Waivers

 

The home care industry is fortunate to have so many experts willing to share their insights and knowledge during this chaotic time. Annette Lee, with Provider Insights, has been a frequent speaker at MAHC events. Annette sent the following email to her home health partners as a quick run down to some of CMS' recent Home Health blanket waivers.

 

As MAHC continues to work on pulling together concise information related to the waivers, I thought this information in the meantime would be helpful. MAHC is also in the process of working with home care experts to bring to you a variety of webinars. Stayed tuned for more information.

 

PLEASE NOTE: Again, MO statute does not currently allow for the provision that allows NP's and PA's to certify and write orders for home health services. MAHC is working with DHSS and will provide more information when available.

 

Email from Annette Lee, Provider Insights:

 

Hello, my HH friends!

 

So, last night, CMS published a "Fact Sheet" of additional blanket waivers and flexibilities provided to the home health industry.  Immediately, we all heard different interpretations. Today, like many of us, I spent the day reading the actual rule (starting on page 64 for HH  https://www.cms.gov/files/document/covid-final-ifc.pdf) and attending CMS, NAHC and NHPCO calls to sift through the details and gain some clarity.  Early in the day, even leaders across the nation were in conflict-- but thankfully, by the end of the day, we have some real clarity-   Information is Power-- So, here is what we know, and I put them in order of what I think was most impactful!  Please share this information freely! 

 

1.) Home health agencies can obtain certifications and orders from NPs and PAs from a federal standpoint now for home health services!  This is already enacted!!  

So, how did this happen?  Last Friday, the CARES Act changed the Social Security Act.  Once the Act was changed, it paved the way- and we all thought we were in a holding pattern until CMS was able to update the regulation within 60 days (that is what I wrote to you last week, right!?)   BUT- on 3/30/20, CMS announced that they were going to have a "Policy of non-enforcement" regarding the regulation which still currently states that Home Health orders must be received from an MD, DO, or DPM.  Only caveat- check with your state if it is within the NP/PA scope.

 

2.) CMS is encouraging HHAs to PLEASE be creative in how we manage patients in this emergency- and part of this is encouraging telehealth, remote monitoring, and other technology. This does NOT mean we document these on our SN notes that flow to our claim. as if we performed a visit... These remote encounters are not billable under the HH benefit.  So, why all the fuss?  Because the "fact sheet" stated "HHAs can provide more service by telehealth"- and could be easily assumed this meant our VISITS could now be remote.  What does it really mean? 

 

CMS is encouraging HHAs to review every patient's plans of care-- determine which visits contain "hands on" components that are essential, such as a complex wound care, IV, injection.  Planned/ordered visits that are not necessarily needing that in person encounter should be considered for a remote encounter.  The plan of care must be updated appropriately and distinguish which visits are to be in person, and which can be remote.  Some examples of visits that may be appropriate for telehealth are: some observation and assessment, teaching, therapies following up on plan established. This is all to reduce the exposure and risk to your team and your patients. 

 

Where to document?

This is not defined by CMS- but they are clear that we do NEED to document these encounters.  So, it may be in a communication note, a coordination of care note, or a SN note that can be "non-billable".  We just must be careful to ensure that the documentation doesn't automatically flow to the home health claim. 

 

Still feel uneasy?  Read it in the full context on page 72 of the interim rule URL at the beginning of the email. 

 

3.) The HHA can certainly assist in facilitating the Face to Face to qualify the patient for home health. Real life situation- you have your first COVID-19 referral. The patient had been tested, but has not seen their physician.  The physician was made aware of their results and made a referral to your HHA to assist the patient as they sheltered at home during their recovery.  You know you must still have a FTF to qualify for HH Medicare benefit- so you call the Dr's office and coordinate a time when you will be at the patient home- and using your front-facing, two way communication platform with video, such as Facetime, you are able to provide the physician with the ability to do a true "Telehealth visit".  This visit will be documented by the physician (how perfect as you can help guide the Dr with what you are seeing and finding as needs!) and billed by the physician- and now, you have your FTF completed!  Boom!

 

4.) 65+?  Comorbids?  HOMEBOUND!! All patients who are high risk (over 65, or any age with chronic diseases such as COPD, cardiac disease or diabetes, etc) can be considered "homebound" during this crisis, because it is medically contraindicated for the patient to leave the home.  This is also true, of course, of any patient who is suspected or confirmed COVID-19 positive.  This should be the statement at the admission and ongoing used to support homebound.  The functional status, may certainly not be indicative of the "normal homebound limitations".  Look at your current census and see if you also may have patients that you are using their Medicaid benefit, because the patient wasn't homebound-- Medicare should now be the payer- if they meet the other criteria. 

 

5.) Assessment timeframes relaxed.  The "initial assessment (484.55a) standard pertains to the 48 hour rule.  The HHA must typically have their first in-person visit within 48 hours to assess just two things: Immediate care needs and if the patient qualifies for home health.  This relaxation states the timeframe can be met by calling the patient and assessing/documenting these things within 48 hours. 

 

The SOC comprehensive assessment timeframe was also relaxed-- up to 30 days to complete the SOC comprehensive assessment, and the 30 day submission rule from M0090 has been waived.  CMS has not indicated how long providers have to submit.  CMS also stated that there will be no penalties from late submissions during the emergency period. 

 

6.) Supervisory visits - Now Remote!  A COP relaxation to decrease exposure available immediately!  The RN may simply call the patient or caregiver and discuss the care provided to ensure she/he can answer the appropriate questions required for a supervisory visit.  Document how this encounter was performed, and of course this is not a billed service. 

 

7.) Payment changes- RAPs remain and 2% raise. Immediately, MACs were instructed to delay the autocancel of RAPs.  This is meant to ensure no further hardship to cashflow during the emergency when the end of episode claims may be late.  What does this mean? CMS will not take back the 20% provided at RAP, until the end of episode claim is submitted for the full amount.  

 

Also beginning with 30-day episodes that begin on May 1st or after, you will see a 2% raise, due to that little thing called "sequestration" being lifted until 12/31/20. 

 

8.) Iowa friends -  It was discussed by IME on 3/30/20 that there is intent to provide guidance that our HH visits WILL be billable to IME and MCOs here in IOWA!  Be watching for that IME email this week!

 

9.) All audits are to be halted.  That's right-- you should not be getting any ADR, RAC, UPIC, etc audit at this time!  Notify me if you do- and I can help you talk with that auditing entity!   If you are in IL, OH or TX, CMS agrees to "PAUSE" Review choice demonstration.  If your agency is doing Pre-Claim Review (PCR), you may want to STRONGLY (hint, hint!) consider continuing to send in your information to Palmetto as PCR.  If you do not, your claims will pay in full, but then after the emergency there will be "some type" of post-pay audit, or TPE, etc to look at the claims that were paid during the emergency.  It is by far riskier to have a full audit, rather than just the documentation needed at the front end for PCR.  Also, a CMS representative stated today that this post pay audit could even include extrapolation ... a word dirtier than any four letters! 

 

10.) There is help...MAC hotlines for advanced payments.  Agencies can request up to three months projected claims income upfront.  In 120 days after payment, the monies will be recouped by the MAC by withholding the billing amounts going forward until paid (expected within 90 days, by day 210) 

 

 If there is one thing that I want to leave you with- and be very clear about is CMS' intent- and our reaction during this period of crisis-- we are to be led by clinical judgement and ethical decision making.  Not everything will be perfect-- it is OK-- do NOT focus your efforts and resources on perfection with COPs at this time-- we will not be surveyed under this emergency unless you have an immediate jeopardy situation.   Do your best, document, keep your patients and your team safe.  That is the best you can do.  If we can do that-- we will get through this!  Hang in there friends!  Can't wait to see you all again!

 

Annette

--

Annette Lee RN, MS, COS-C

Provider Insights, Inc.

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Information Released by MAHC on April 1, 2020:

 

3-30-20 UPDATED COVID-19 Emergency Guidance
Released for HCBS Providers

 

The COVID-19 Emergency Guidance has been updated again.  Providers should review all sections identified as new or updated for the latest guidelines.

 

Click on the following link to access the HCBS Provider Information Page that includes the UPDATED Emergency Guidance: https://health.mo.gov/seniors/hcbs/covid-19-provider-info.php  or click here for a PDF version.

 

Updated Sections:

A personal protective equipment (PPE) update letter from the Department of Health and Senior Services (DHSS) has also been added to the Provider Resources folder.

 

Any questions regarding this information should be directed to Long Term Services and Supports via email at ltss@health.mo.gov.

 

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CMS Issues New Waivers under the Home Health Conditions of Participation and Waivers for Hospice

As I reported earlier, on March 30, 2020 the Centers for Medicare & Medicaid Services (CMS) announced an Emergency Declaration of Blanket Waivers and Flexibilities for health care providers.  CMS stated the following about the waivers:  the following blanket waivers are in effect, with a retroactive effective date of March 1, 2020 through the end of the emergency declaration.

 

Below is another recap of the recent waivers. I have noted some clarifications based on questions we have received. Please continue to let me know your questions and we will continue to seek additional clarification.

 

I do realize how confusing all this information is for everyone.  Please continue to be patient with us as we try to provide you the most up-to-date information (while also experiencing staffing limits). We will attempt to consolidate information as much as possible knowing this is a fluid situation that constantly changes.

 

Home Health

https://www.cms.gov/files/document/covid-home-health-agencies.pdf

 

The Centers for Medicare & Medicaid Services (CMS) has waived some significant provisions of the home health Conditions of Participation. The following items under the CoP have been waived by CMS.

  1. The initial evaluation under 484.55 (a) will not require an on-site visit and may be conducted remotely or through medical review. PLEASE NOTE: This does not apply to the comprehensive assessment requirement under 484.55(b).Allowing HHAs to conduct the initial evaluation in this manner will help agencies comply with 48-hour rule for the initial evaluation visit if agencies are required to conduct an on-site visit to determine eligibility and immediate care.
  2. The waiver includes extending of the 5-day completion requirement for the comprehensive assessment and waiving the 30-day OASIS submission requirement. HHAs are expected to complete the comprehensive assessment within 30 days and delayed submission is permitted.
  3. 14-day HCA supervisory visits are waived during the public health emergency (PHE). CMS encourages virtual supervision, but it is not a requirement.
  4. Several coverage and payment requirements have also been waived that include:
    • extending the time frame for auto-cancellation of requests for advanced payments (RAPs);
    • NPPs may certify and write orders for home health services (PLEASE NOTE: MAHC is in the process of determining if this will be allowed under current MO law and regulations and if within the disciplines' scope of practice - MAHC will provide more details as soon as possible; therefore we recommend you do not follow this guidance until clarification on the state level can be made);
    • physician face-to-face encounters may be conducted using two-way audio/visual communication;
    • homebound status based on a physician order indicating that leaving the home is medically contraindicated (PLEASE NOTE: THIS MUST BE RECORDED IN THE PLAN OF CARE);
    • extended time frame for request for advanced payment auto cancel.
  5. Agencies may provide visits through telehealth or any two audio/visual technology and not be subject to HIPAA compliance enforcement. The visits must be ordered by the physician and on the Plan of Care. Telehealth may substitute for an ordered on-site visit but will not count towards the LUPA threshold. And, unfortunately, agencies may not receive reimbursement for telehealth visits. (click here for our supplemental information related to CMS' decision - information includes link to the Interim Final Rule)
  6. Flexibilities under Medical review include halting targeted probe and educate reviews. Any additional documentation request (ADR) that has been requested will be withdrawn and the claim will process and be paid. CMS is pausing review choice demonstration (RCD) in Illinois, Ohio, and Texas. North Carolina and Florida will not begin on May 4, as previously scheduled. All claims submitted will be processed and paid and not be subject to a 25 percent reduction. Agencies wanting to continue with pre-payment review under RCD may do so.

Hospice Waivers & Flexibilities
https://www.cms.gov/files/document/covid-hospices.pdf


Hospice Services Using Telecommunications Systems
A key challenge that has arisen for hospice providers during the pandemic has been continuing access to hospice patients, particularly given growing limitations set around entry to nursing facilities and other congregate sites and concerns of vulnerable hospice patients about allowing entry to their homes an potential exposure to COVID-19. As part of the recently released interim final rule, the Centers for Medicare & Medicaid Services (CMS) has provided some relief. These changes are effective retroactive to March 1.

 

Hospice Face-to-Face Encounter
The interim final rule allows a hospice physician or hospice nurse practitioner (NP) to conduct the encounter using "telehealth" if the visit is solely for the purpose of fulfilling the recertification requirement, and if the hospice employs telecommunications technology that allows for audio and video permitting two-way, real time interactive communications. It should be noted that the Health and Human Services Office for Civil Rights has waived HIPAA concerns for these purposes and is now allowing use of non-public facing technologies, including Skype and similar platforms.

Delivery of Hospice Services Using Telecommunications Systems
Also for the duration of the public health emergency, CMS is modifying regulations to allow hospices to provide services under the Routine Home Care (RHC) level of care using telecommunications systems. CMS specifies that it must be feasible and appropriate to use telecommunications-based visits to ensure patients can continue to receive services and that the services are reasonable and necessary for the palliation and management of a patient's terminal illness without jeopardizing the patient's health or that of the hospice care provider. Use of such technology must be included in the plan of care and tied to patient-specific needs. No payment will be permitted for such visits, and CMS notes that only in-person visits may be submitted on claims (with the exception of social worker calls). Hospices may report telecommunications technologies on their cost reports.

CMS does not otherwise provide specifications around the definition of telecommunications technologies for these purposes. More clarification is needed.

Hospice Telehealth for Physician Medical Services
During the COVID-19 emergency, CMS is taking additional steps to permit use of telehealth to deliver hospice medical services. Earlier this month, the HHS Secretary waived telehealth requirements to allow use of a patient's home and other locations as an "originating site" and eliminated existing requirements that only allowed telehealth services to be delivered in rural areas. That waiver also allows for use of telephones, but requires that they have two-way audio-video capabilities and operate in real time. For the period of the emergency, HIPAA requirements have also been waived relative to telehealth to allow use of non-public facing platforms such as Skype.

CMS has further indicated that medical services provided by a hospice physician or hospice-employed NP may be provided via telehealth and billed by the hospice provided the physician or NP is the hospice patient's designated attending physician.

 

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CARES Act & Families First Coronavirus Response Act -

Opportunities for Employers & Employees - Resources Available

 

Now that "home care" has been recognized under the Department of Labor's definition of health care, as it relates to the implementation of the Families First Coronavirus Response Act, employers have some tough decisions ahead.

 

As all of you know, your essential caregivers may or will serve those afflicted with COVID-19 as well continuing to serve thousands more who have unrelated care needs while also at the risk of contracting COVID-19. While the goal is to keep our crucial caregivers in place to assist Missouri's ability to cope with the pandemic crisis, we also encourage providers to continue to be responsive to your employees' needs, to the fullest extent possible.

 

On March 27, President Trump singed into law the Coronavirus Aid, Relief, and Economic Security (CARES) Act. This bill provides easy access to loans and other economic assistance to businesses of all sizes and provides aid and support to healthcare providers. There are now programs available from the federal government and the Small Business Administration, such as the paycheck protection program, that will ensure agencies can afford to pay their caregivers should they need time off to care for themselves or other family members. 

 

The CARES Act also did modify the Families First Coronavirus Response Act in several ways. Click here for a summary of the significant provisions provided by our partner, SESCO Management Group.

 

We know there is an abundance of information available related to the loan relief opportunities within the CARES Act. Below is additional valuable information from MAHC's partners that we hope you find helpful:

 

SESCO Management Group - Small Business Interruption Loans under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act)

 

Husch Blackwell - Stimulus Bill Update: Additional SBA Relief Available to Coronavirus-Impacted Small Business

 

 

 

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Information Released by MAHC on March 31, 2020:

 

CMS Issues Additional Home Health and Hospice Flexibilities

 

Late yesterday, March 30, CMS issued significant rule changes, waivers of certain conditions of participation, and a series of interpretations of hospice and home health requirements designed to relieve pressures and increase flexibilities during the pandemic crisis.  All told, the outcome is a mixed bag.  That means there is still a lot of work to do to break down the barriers to efficient and effective care.

 

(Click here for CMS' Home Health Agencies: CMS Flexibilities to Fight COVID-19)

 

While I am still combing through all the items, NAHC President, Bill Dombi has provided a summary that I wanted to share with you to alleviate a few questions you may already have. I will provide more information as I continue get through all the information.

 

In the meantime, here is a summary list of the changes from NAHC:

 

We start with the disappointment. CMS issued an emergency interim final rule that addresses the industry-wide priority of increasing flexibility in the use of telehealth. The goal was to gain opportunities to provide telehealth as a means to maximize the availability of staff for in person visits when no alternative was possible, reduce demand on PPE, increase discharges from inpatient hospitals to free up needed beds, reduce exposures of patients and caregivers, and mitigate concerns or virus transmissions that have led to patients refusing needed care.  To do all that, HHAs simply asked to get paid for telehealth services.

 

CMS recognized the high value of telehealth and the potential to achieve significant outcomes such as the ones referenced above. However, CMS determined that the law did not allow it to pay HHAs for telehealth.  That means we must go back to Congress to change the law or we must change CMS's view of the law. In the meantime, HHAs should see expanded telehealth as a means to reduce episode costs. CMS, in fact, offered an illustration of how physician-ordered telehealth might reduce the need for in-person visits while not triggering a reduction in reimbursement as the LUPA threshold was met.  As such, CMS sees telehealth not as something to pay for, but rather something to reduce HHA costs. We strongly disagree with CMS that payment for telehealth is not warranted.  We vow to fight on!

 

The CMS policy does allow HHAs to record the cost of all telehealth services in the cost report. Big deal! That might affect reimbursement rates five years from now. However, we do very much appreciate that CMS sees great value in telehealth. The discussion of such in the rule is a clear indication that CMS understands and accepts the value of telehealth provided by HHAs.

 

As a side note, CMS does pose a limited option for HHAs. That option would have the HHA contract with a physician or NPP to provide the telehealth to patients. The physician or NPP would then bill for the telehealth service and pay the contracted rate to the HHA. CMS cautions though that such action may be a concern if it is done within a home health services covered episode.

 

HHAs have long recognized that telehealth could reduce visit volume needs. CMS now also recognizes that outcome. Going forward, CMS wants HHAs to use more telehealth. A key is that it must be physician ordered rather than the HHA choosing to substitute telehealth when in person visits are ordered.. Still, it will not add any reimbursement. It will only have the potential reduce costs. NAHC fully intends to continue an aggressive push to the real change that is needed-payment for telehealth..

 

 The changes do have a number of significant upsides. Those are:

 

 HOME HEALTH SERVICES 

  1. A definition of the home health "homebound" requirement that means that any individual determined by their physician to be at high risk of contracting Covid-19 virus due to a compromised health condition, meets the homebound requirement because it is "medically contraindicated" to leave the home.
  2. A waiver of numerous Conditions of Participation, including:
    •  Onsite visit for home health aide supervision
    • In person initial patient assessments. Instead, HHAs can provide these assessments remotely or by record review
  3. Utilizing enforcement direction to permit non-physician practitioners (NP, PA, and CNS) to certify eligibility for the home health benefits and to establish and manage the Plan of Care provided such is allowable under state practice laws.  This change was mandated at part of the CARES Act enacted into law last week. However, CMS has been able to accelerate its implementation through its enforcement discretion authority.
  4. Suspend all medical review audits other than in cases of fraud investigation
  5.  Suspend the Review Choice Demonstration program. HHAs will have the choice to continue with pre-claim review if they wish. Other claims will be subject to possible post-payment review. RCD will not expand into Florida and North Carolina as originally planned for May.  No new date has been set for that expansion.

 HOSPICE SERVICES

  1. Allowance to use telehealth for the physician face-to-face encounter requirement. This was mandated as part of the CARES Act. However, CMS determined it had the authority to make that change under its own authority. Effectively, this action speeds up the implementation.
  2. Permit the billing of telehealth services by hospice physicians
  3. Waive the requirement for hospices to use volunteers
  4. Waive timeframes for updating comprehensive patient assessments extended the deadline from 15 to 21 days
  5. Waive the non-core services requirements that include physical therapy, occupational therapy, and speech-language pathology
  6. Waive the 14-day home health aide in-person supervisory requirements same as in home healthSuspend all medical review audits other than in cases of fraud investigation

These changes are in addition to those earlier announced that include the establishment of an Accelerated and Advance Payment program, permitting home health F2F encounters by telehealth, and suspending the auto-cancellation RAP program.  CMS also permitted allowances for extending appeal deadlines and some provider enrollment requirements.

 

All told, there are many positives in today's actions by CMS. Still, we have more to do. We especially are not finished with telehealth reform advocacy. Stay tuned on that.

 

 These changes can be found at:

 

 https://www.cms.gov/about-cms/emergency-preparedness-response-operations/current-emergencies/coronavirus-waivers

 

 https://www.cms.gov/newsroom/press-releases/trump-administration-makes-sweeping-regulatory-changes-help-us-healthcare-system-address-covid-19

 

 https://www.cms.gov/files/document/provider-burden-relief-faqs.pdf

 

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Information Released by MAHC on March 30, 2020:

 

DOL Issues Guidance on Extended Sick 

and FMLA Leave Under Covid-19 Stimulus Bills - 

Home Care IS Included in "Health Care Provider" Definition

 

The US Department of Labor issued guidance Saturday on standards and application of the extended sick and FMLA leave under the recent Covid-19 stimulus bills.

https://www.dol.gov/agencies/whd/pandemic/ffcra-questions 

 

The guidance addresses an important issue affecting home care and hospice companies. MAHC, NAHC and others sought to have an exemption applicable to a "health care provider" to apply to the workforce in home care and hospice as they are essential to the care needs of the whole population during the pandemic. The exemption would affect health care workers who otherwise would qualify for sick leave and family leave when they cannot work due to school or childcare services closings and unavailability.  

 

The DOL guidance provides an exemption of employees of a "home health" company. While those of us involved in home care consider that term to be limiting rather than encompassing the broad array of companies providing health services in the home, further elements of the guidance make it clear that it encompasses the full range of home care and its employees.

 

Specifically, the guidance states: 

Who is a "health care provider" who may be excluded by their employer from paid sick leave and/or expanded family and medical leave?  For the purposes of employees who may be exempted from paid sick leave or expanded family and medical leave by their employer under the FFCRA, a health care provider is anyone employed at any doctor's office, hospital, health care center, clinic, post-secondary educational institution offering health care instruction, medical school, local health department or agency, nursing facility, retirement facility, nursing home, home health care provider, any facility that performs laboratory or medical testing, pharmacy, or any similar institution, employer, or entity. This includes any permanent or temporary institution, facility, location, or site where medical services are provided that are similar to such institutions.

 

This definition includes any individual employed by an entity that contracts with any of the above institutions, employers, or entities institutions to provide services or to maintain the operation of the facility.

 

This also includes anyone employed by any entity that provides medical services, produces medical products, or is otherwise involved in the making of COVID-19 related medical equipment, tests, drugs, vaccines, diagnostic vehicles, or treatments. This also includes any individual that the highest official of a state or territory, including the District of Columbia, determines is a health care provider necessary for that state's or territory's or the District of Columbia's response to COVID-19.

To minimize the spread of the virus associated with COVID-19, the Department encourages employers to be judicious when using this definition to exempt health care providers from the provisions of the FFCRA.

 

NAHC's view is that the reference to "any similar institution, employer, or entity" combined with longstanding DOL classification of individuals providing personal care service in the home as health care workers results in the conclusion that home health agencies, personal care services companies, private duty nursing employers, and hospices are all within DOL's exemption of a "home health care provider."  

 

For example, the Department of Labor has long maintained within a health care worker category 31-1011 Home Health Aides:

Provide routine individualized healthcare such as changing bandages and dressing wounds, and applying topical medications to the elderly, convalescents, or persons with disabilities at the patient's home or in a care facility. Monitor or report changes in health status. May also provide personal care such as bathing, dressing, and grooming of patient.

 

Further support is found in the reference to a "retirement facility" distinct from a "nursing facility." At most, a retirement facility provides personal care.

Finally, note also that the exemption goes beyond direct service employees and "includes any individual employed by an entity that contracts with any of the above institutions, employers, or entities institutions to provide services or to maintain the operation of the facility."

 

NAHC has confirmed the appropriateness of this interpretation through outside counsel.

 

NAHC also advises that the home care and hospice community fully review all aspects of the extended leave standards as there will be instances when they still apply to your workforce.

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Information Released by MAHC on March 27, 2020:

 

Good News!

Some Home Health and Hospice Issues Approved in
Missouri Hospital Association 1135 Waiver Request

 

We are glad to see that certain requests related to Home Health and Hospice in the Missouri Hospital Association's (MHA) 1135 Waiver submitted to CMS has been approved. The Missouri Alliance for Home Care (MAHC) has also submitted a waiver request, which included the following, plus additional requests. Based on MHA's response from CMS, we are hopeful many of our additional requests will also be approved. We will have to wait and see but, in the meantime, the following waivers have been granted. Some will most likely need additional clarification. We will let you know as soon as we receive.

 

Home Health Agencies:

 

 * Reporting: Provides relief to Home Health Agencies on the timeframes related to OASIS Transmission. (Approved on 3/13/2020- Clarified) This waiver includes:

o Extension of the 5-day completion requirement for the comprehensive assessment

o Waives the 30-day OASIS submission requirement

 

* Home Health 42 C.F.R. § 484.55(a). Home health agencies can perform initial assessments and determine patients' homebound status remotely or by record review. This will allow patients to be cared for in the best environment while supporting infection control and reducing impact on acute care and long-term care facilities. This will allow for maximizing coverage by already scarce physician and advanced practice clinicians and allow those clinicians to focus on caring for patients with the greatest acuity.

 

 

Hospice:

 

 * Waive requirement for hospices to use volunteers. CMS is waiving the requirement that hospices are required to use volunteers (including at least 5% of patient care hours). It is anticipated that hospice volunteer availability and use will be reduced related to COVID-19 surge and anticipated quarantine. (42 CFR §418.78(e))

 

* Comprehensive Assessments: CMS is waiving certain requirements for Hospice (§418.54) related to update of the comprehensive assessments of patients. This waiver applies the timeframes for updates to the comprehensive assessment (§418.54(d)). Hospices must continue to complete the required assessments and updates, however, the timeframes for updating the assessment may be extended from 15 to 21 days.

 

* Waive Non-Core Services: CMS is waiving the requirement for hospices to provide certain non-core hospice services during the national emergency, including the requirements at §418.72 for physical therapy, occupational therapy, and speech-language pathology.

 

 

Home Health & Hospice:

 

* Waived onsite visits for both HHA and Hospice & Aide Supervision: CMS is waiving the requirements at 42 CFR 418.76 (h) and 484.80(h), which require a nurse to conduct an onsite visit every two weeks. This would include waiving the requirements for a nurse or other professional to conduct an onsite visit every two weeks to evaluate if aides are providing care consistent with the care plan as this may not be physically possible for a period of time. This waiver is also temporarily suspending 2-week aide supervision requirement at 42 CFR §484.80(h)(1) by a registered nurse for home health agencies, but virtual supervision is encouraged during the period of the waiver.

 

 

Click here to see CMS' response letter to MHA.

 

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Various COVID-19 Info for Home Health and Hospice

Click here to download the specific information related to the above topics.

 

 

Information Released by MAHC on March 26, 2020:

 

Stimulus Bill Heads to House - Home Care & Hospice Provision Included

 

Late last night the Senate passed the $2 trillion stimulus bill by a vote of 96-0. This bill now moves to the House for their consideration where it is expected to be approved tomorrow morning. The prime focus of the bill is widespread relief to workers, business, and more.  It does contain several Medicare and Medicaid provisions of relevance for the home care and hospice community.

 

Provisions impacting home care and hospice are as follows:

  1. Use of Telehealth for Hospice Face-to-Face Encounters during Recert Process - Permits hospice F2Fencounters to be performed through telehealth during the emergency period, "as determined appropriate by the Secretary." Specific guidance must come from CMS.  It is not yet known what forms of telehealth CMS may approve. (Section 3706)
  2. Encouraging Use of Telecommunications for Home Health Service - This provision does not create any certain telehealth relief measures such as reimbursement. Instead, it shifts decision-making to CMS to determine what it can do within its authority. Requires CMS to issue clarifying guidance encouraging the use of telecommunications systems, to furnish home health services. (Section 3707)
  3. Allowing Non-Physician Practitioners to Certify Medicare Home Health Benefit Eligibility - This provision would finally change the requirements that only a physician can authorize a plan of care and certify benefit eligibility. If passed, CMS would still need to change rules to implement it. (Section 3708)
  4. Suspension of 2% Sequester - This provision would increase all provider payments by 2% effective May 1, 2020 through December 31, 2020. At this point it is uncertain if it relates to claims paid during that period or services rendered. Best assumption is that the time period is services rendered. (Section 3709)
  5. Providing Home and Community-Based Services in Acute Care Hospitals - This provision appears to be a way of extending the nature of HCBS waiver services into a hospital setting to reduce length of stay and free up beds. (Section 3715)

The national arm of MAHC's lobby firm, Husch Blackwell Strategies has shared their March 25, 2020 COVID-19 daily update that includes a breakdown by section, what is included in the Senate stimulus bill (our specific section number are noted above).  Click here to read the March 25, 2020 update for specific details.

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Coronavirus Response Act with Emergency Paid Sick Leave -
Call to Action and Valuable MAHC Member Benefit Resources Available

 

NOTE: Exemptions for Health Care Providers Require Revision to Cover Some Home Care, Hospice Personnel

On Wednesday, March 18, President Donald J. Trump signed into law H.R. 6021 (P.L. 116-127), The Families First Coronavirus Response Act, which expands access to Emergency Paid Sick Leave to as many as 87 million U.S. workers, and provides families with Emergency Paid Family Leave to address widespread and potentially prolonged school closures due to Coronavirus.

 

The legislation acknowledges the great demand for health care providers during the growing public health emergency and allows for a limited exception that is available to employers of "health care providers".  PLEASE NOTE:  At this time the regulatory definition of "health care provider" for purposes of the Family and Medical Leave Act (FMLA) is limited to physicians and other practitioners, and does not extend to RNs/LPNs/LVNs, home health or hospice aides, or various other home care and hospice personnel.

The Missouri Alliance for Home Care (MAHC) in conjunction with the National Association for Home Care & Hospice (NAHC) and other associations are working to secure legislative and/or regulatory revisions that would support the important work of home care and hospice entities and allow them to exclude a broader range of staff from the requirements to ensure that they can continue to provide quality care to vulnerable patients throughout the pandemic.  These provisions are effective no later than 15 days following enactment, providing the Department of Labor (DOL) leeway to issue rules providing clarification around issues addressed in the legislation.

 

Click here to view MAHC's letter sent to the Department of Labor that outlines MAHC's rationale for recommending the above-changes to the definition of "health care provider." 

 

CALL TO ACTION:  We encourage you to write to the Department of Labor to support this expansion of the definition.  Given the limited time frame action must be taken as soon as possible. Click here on how to submit your letter.

 

Valuable Resources for Employers

Also, as a MAHC member benefit, you have access to our Management Consulting firm, SESCO. The following are VALUABLE resources for employers related to COVID-19. We highly suggest you bookmark these links and check back often as they will be updated frequently.

 

MAHC member benefit - SESCO Management Consultants Resources

Daily Staff Recommendations:
The SESCO Staff continues to meet daily and discuss all developments of the Emergency Paid Family and Medical Leave. Click on the link below for the most up-to-date Staff recommendation. SESCO is in communication with The Department of Labor ("DOL") attempting to obtain answers and clarification on a number of questions that were absent from the Families First Coronavirus Response Act ("FFCRA" or "Act"). As such, they will continue to update the information as they learn more.

 

Click here for the full Staff Recommendation.

 

COVID-19 Employer General Frequently Asked Questions:
Many employment-related issues face employers in the wake of COVID-19.  SESCO has created a Frequently Asked Questions (FAQ) document, which has been continually updated since first published and will continue to be updated as events warrant.

 

To view the full list of questions and answers click here.

 

Posting Requirement under the Families First Coronavirus Response Act (FFCRA):
Each covered employer must post a notice of the FFCRA requirements in a conspicuous place on its premises. An employer may satisfy this requirement by emailing or direct mailing this notice to employees or posting this notice on an employee information internal or external website. 

 

The notice can be accessed on SESCO's website by clicking here.

 

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3-25-20 UPDATED COVID-19 Emergency Guidance
Released for HCBS Providers

 

The COVID-19 Emergency Guidance has been updated again.  Providers should review all sections identified as new or updated for the latest guidelines.

 

Click on the following link to access the HCBS Provider Information Page that includes the UPDATED Emergency Guidance: https://health.mo.gov/seniors/hcbs/covid-19-provider-info.php  or click here for a PDF version.

 

New Sections:

 Updated Sections:

Any questions regarding this information should be directed to Long Term Services and Supports via email at ltss@health.mo.gov.

 

COVID-19 Guidance - HCBS Intake Center and Person Centered 

Care Planning (PCCP) Team Operations 

 

 As a result of the ongoing COVID-19 outbreak, the HCBS Intake Center will no longer be conducting preliminary prescreen Level of Care (LOC) determination on participants. All HCBS Intake Center staff will be reallocated to support the PCCP Team (formerly known as REV Team) to create a statewide call center to support telephone operations.

Instead of conducting a telephone prescreen on potential participants, the HCBS Intake Center will be ensuring information regarding referrals for initial assessments are given to DSDS assessor staff to determine initial LOC over the telephone. The PCCP Team will continue to complete all orders for care plan changes.

 

In an effort to preserve the phone lines for participants, e-mail or fax is the preferred method to submit referrals or communication to HCBS Intake Center and PCCP Team. Please send information to the appropriate email address/fax number (see below) to ensure timely processing. The following forms may be used to submit the requests/referrals. All e-mails must be encrypted to protect the participant's privacy.

 

Provider Communication Form
Initial Referral Form

Initial Referrals: Fax: 573/526-2915

 

Email: HCBSCallCenterReferrals@health.mo.gov

 

PCCP Teams - Care Plan/Provider Change Requests:

PCCP 1: REV1@health.mo.gov or by fax to 417/895-1341
PCCP2: REV2@health.mo.gov or by fax to 573/290-5650
PCCP3: REV3@health.mo.gov or by fax to 314/340-3467
PCCP4: REV4@health.mo.gov or by fax to 816/889-2004
PCCP5: REV5@health.mo.gov or by fax to 573/884-4884

 

Questions regarding this memorandum should be directed to the Bureau of Long Term Services and Supports (BLTSS) via e-mail at LTSS@health.mo.gov or by telephone at 573-526-8557.

 

To access the full memo, click on the following link and refer to
INFO-03-20-03 https://health.mo.gov/seniors/hcbs/infomemos.php

 

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Information Released by MAHC on March 23, 2020:

 

DHSS Releases Updated Memo - 

Guidance on Hospice Care in Long-Term Care Facilities

 

On March 20th, the Department of Health & Senior Services (DHSS) sent a updated memo – Guidance on Hospice in Long-Term Care Facilities to all Missouri Long-Term Care facilities and Hospice providers.  MAHC is continuing our communications with the Section for Long-Term Care, the Bureau of Home Care & Rehab Standards and the Division of Regulation and Licensure all within DHSS related to concerns denying hospice personnel into nursing facilities.

 

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3-23-20 UPDATED COVID-19 Emergency Guidance
Released for HCBS Providers

 

The COVID-19 Emergency Guidance has been updated again.  Providers should review all sections identified as new or updated for the latest guidelines.

https://health.mo.gov/seniors/hcbs/covid-19-provider-info.php

 

New Sections:

 Updated Sections:

 Additional resources have also been added to the "Resource" tab. 

 

Any questions regarding this information should be directed to Long Term Services and Supports via email at ltss@health.mo.gov.

 

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COVID-19 Childcare Needs Assessment for Staff

 

In an effort to support continuing operations of critical services during the COVID-19 outbreak, the State of Missouri is working to identify the childcare needs of essential health care staff, which includes Home Health, Hospice, HCBS and Private Duty provider staff.

 

Please distribute the following link to staff who are in need of childcare services in order to remain at work: https://stateofmissouri.wufoo.com/forms/m1cs1vfl1dde8dt/

 

The State will collect this information and coordinate with local school districts and other resources to determine available options. Additional information will be shared with affected parties as it becomes available.

 

At this point this is information gathering to see what options might be available. While not many details are yet available if anyone has questions please contact childcare@health.mo.gov.

 

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Information Released by MAHC on March 19, 2020:

 

 

UPDATED COVID-19 Emergency Guidance
Released for HCBS Providers

 

The COVID-19 Emergency Guidance has been updated.  Providers should review all sections identified as new or updated for the latest guidelines.

 

Click on the following link to access the HCBS Provider Information Page that includes the UPDATED Emergency Guidance: https://health.mo.gov/seniors/hcbs/covid-19-provider-info.php or click here for a PDF version.

 

New Sections:

 

Updated Sections:

 

Any questions regarding this information should be directed to Long Term Services and Supports via email at ltss@health.mo.gov.

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Information Released by MAHC on March 18, 2020:

 

Home Health & Hospice

CMS Issues Regulatory Waivers in Response to COVID-19

(from NAHC Report)

 

For the full report click here

 

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COVID-19 Emergency Guidance Released for HCBS Providers

 

The Division of Senior and Disability Services (DSDS) released the following notice:

 

Please refer to the following COVID-19 HCBS Provider Information page for up to date guidance related to the outbreak.  As new information arises the page will be updated and a DSDS e-news blast will be sent out notifying providers of any changes.  Please check your email daily for new notifications.

 

Click on the following link to access the HCBS Provider Information Page that includes the Emergency Guidance: https://health.mo.gov/seniors/hcbs/covid-19-provider-info.php

 

        (or click here for a PDF version of the Guidance)

 

DSDS has also requested that we ask providers to email questions instead of calling right now as they are also experiencing staffing shortages due to school closures.

 

Also, I encourage members to continue to reach out to MAHC related to further issues or needs that arise due to the COVID-19 pandemic.

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Information Released by MAHC on March 17, 2020:

 

 Additional daily info related to the COVID-19 situation - 

 

 

Private Duty Nursing (PDN) Services - COVID-19 Changes

 

MAHC is working diligently to advocate for waivers and other measures to assist all providers during this challenging time. Today, MO HealthNet released a bulletin that includes changes to Private Duty Nursing (PDN) services processes due to the ongoing COVID-19 outbreak.

 

Click here to access the memo.

 

DSDS & DMH Letter to HCBS Providers

 

Division of Senior and Disability Services (DSDS) and Department of Mental Health (DMH) leadership release letter regarding updated information and guidance for HCBS providers related to COVID-19.

 

Click here to access the letter.

 

Coronavirus COVID-19 Homecare and Hospice Checklist:
What You Should Be Doing Now as of Date 3/16/2020

 

Barbara Citarella of RBC Limited Healthcare & Management Consultants has created a REVISED checklist for the current situation related to the COVID-19 pandemic.

 

Click here to access the REVISED Checklist.

 

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Information Released by MAHC on March 16, 2020:

 

Additional info related to the COVID-19 situation - 

 

Early Prescription Refill

 

On March 13, 2020, the Missouri Department of Social Services issued a provider bulletin changing the early refill policy for medications from 85% to 50% for controlled and non-controlled substances.  This will allow participants to have over 15 days of medication on hand should they need to be quarantined or be practicing self-quarantine.  Please encourage and assist your patients/clients to utilize this flexibility to increase the amount of medications they have on hand.

 

Click here to see the memo. 

 

COVID-19 Long-Term Care Facilities Visitor Restrictions

 

The Department of Health & Senior Services (DHSS) sent the following information to Missouri Long-Term Care facilities this past weekend. MAHC continued communications with the Section for Long-Term Care at DHSS related to concerns denying hospice personnel into nursing facilities.

 

The DHSS guidance applies to all long-term care facilities including residential care facilities, assisted living facilities, intermediate care facilities, skilled nursing facilities, and intermediate care facilities for persons with intellectual disabilities. The guidance states:

In response to the COVID-19 concern DHSS is instructing facilities to impose restrictions on visitors. These recommendations include but are not limited to the following:

 

 Exceptions to restrictions:

Click here to access the full memo.

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As a follow-up to the information released by MAHC on Friday, March 13, 2020, DHSS has released the following information related to the process and requests for PPE:

 PPE Resource Process and Requests

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Information Released by MAHC on March 13, 2020:

 

EFFECTIVE IMMEDIATELY 

 Home & Community Based Services (HCBS) 

A memorandum has been issued regarding the need to conduct all assessments via telephone, effective immediately for Home & Community Based Services.

 

Please refer INFO-03-20-01 at the link provided below.

 

https://health.mo.gov/seniors/hcbs/infomemos.php

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IMPORTANT INFORMATION FOR REQUESTING PPE SUPPLIES

 Home Health, Hospice & HCBS Providers

Based on our conversations with DHSS related to PPE supplies please see the following guidance we received this morning. 

 

Providers should contact either their local county health department or local emergency manager and ask that they make the request vie WebEOC, or they can email DRMS@health.mo.gov directly with their requests. They will need to add a justification for why they need the PPE and exactly what they need. The EOC will start reviewing the requests next week but suggested that providers make their requests now so they are already in the system.

 

CDC information: https://www.cdc.gov/coronavirus/2019-ncov/hcp/healthcare-supply-ppe-index.html on the supply of PPE including N95 masks. It is best for providers to check with their local emergency preparedness officials (state department of health, coalition, etc.) regarding local supplies.

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CMS NEWS: CMS Publishes FAQs to Ensure Individuals, Issuers and States have Clear Information on Coverage Benefits for COVID-19

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COVID-19 Resources for State Agencies – Specific Home Care Resources Below

ADvancing States represents the nation’s 56 state and territorial agencies on aging and disabilities and long-term services and supports directors and has compiled COVID-19 resources relevant to the aging and disability networks. This web page includes the latest federal guidance from ACL, CMS, and the CDC. You can also view materials from other state agencies.

Learn more at: www.advancingstates.org/covid-19

The site has links to a collection of COVID-19 resources and guidance produced by state health departments and agencies.  Below are a few examples you may find helpful:

North Carolina
Guidance on considerations of people with disabilities and other access and functional needs for COVID-19 

 

Texas
Tips for the public: Managing your stress related to COVID-19

Tips for health professionals: Managing your stress related to COVID-19

Vermont
Recommended Precautions for Caregivers

Virginia
Pandemic preparedness checklist

Washington State
Memo with information for Home Care Providers
Guidance for In-Home Care Providers

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Information Released by MAHC on March 11, 2020:

 

 CMS Sends More Detailed Guidance to Providers about COVID-19


Home Health -   Latest group to receive important information on protecting staff and at-risk patients. Click here to view CMS' guidance for home health providers.  

 

Hospice - there has been discussion around hospice providers who are being told by nursing homes that they are not permitted to enter the homes to care for their patients on hospice care because the nursing home has instituted a no visitor policy.  On March 9, CMS issued separate guidance for hospices and for nursing homes that references appropriate procedure relative to these circumstances:

 

Revised Nursing home guidance:  https://www.cms.gov/files/document/qso-20-14-nh-revised.pdf

Excerpt from pp. 3-4:  5. Facilities should review and revise how they interact with volunteers, vendors and receiving supplies, agency staff, EMS personnel and equipment, transportation providers (e.g., when taking residents to offsite appointments, etc.), other practitioners (e.g., hospice workers, specialists, physical therapy, etc.), and take necessary actions to prevent any potential transmission. For example, do not have supply vendors transport supplies inside the facility. Have them dropped off at a dedicated location (e.g., loading dock). Facilities can allow entry of these visitors as long as they are following the appropriate CDC guidelines for Transmission-Based Precautions. For example, hospice workers can enter a facility when using PPE properly.

 

Hospice guidance:  https://www.cms.gov/files/document/qso-20-16-hospice.pdf
 Excerpt from page 6:  If hospice care is provided in a nursing home, we have advised nursing homes that hospice workers should be allowed entry provided that hospice staff is following the appropriate CDC guidelines for Transmission-Based Precautions, and using PPE properly.

 

Medicare Advantage and Part D Plans - 

 Click here to view CMS' memorandum for MA and Part D plans.

 

Key Protective Mask Guidance for Healthcare Workers - 

The memo clarifies the application of CMS policies in light of recent Centers for Disease Control and Prevention (CDC) and Food and Drug Administration (FDA) guidance expanding the types of facemasks healthcare workers may use in situations involving COVID-19 and other respiratory infections.  Click here to view the memo.


The memo aligns CMS policy with recent changes to CDC and FDA facemask and respirator guidance in light of COVID-19 and supply demands. To help reduce burden on healthcare facilities at this time, the CMS memo implements CDC guidance by stating that facemasks, which protect the wearer from splashes and sprays, are an acceptable temporary alternative to respirators, which filter the air, for most medical services until demand for respirators lessens.

 

 
NAHC Website Offers New Tools for COVID-19

 

The National Association for Home Care & Hospice (NAHC) wants to make you aware that there are three new tools added to the NAHC coronavirus webpage:

These resources were developed by NAHC and are provided in a format that allows you to customize them for use with your patients.

 

Missouri Opens Novel Coronavirus Information Hotline

 

The Missouri Department of Health and Senior Services (DHSS) activated a statewide public hotline for citizens or providers needing guidance regarding the novel coronavirus, or COVID-19. At 8 a.m. today, the hotline opened and can be reached at 877-435-8411. The hotline is being operated by medical professionals and is available 24 hours a day, 7 days a week.

 

"Communication is vital to our response to this rapidly-evolving situation," said Dr. Randall Williams, director of DHSS. "For several weeks, our COVID-19 webpage has been and continues to be a great resource for the public, but having the hotline as an additional resource will likely be invaluable as citizens seek guidance for their concerns."

 

To date, 46 patients in Missouri have been tested for the virus that causes COVID-19; one of those has tested positive.

 

"It is important to know what to do if you have concerns about an illness during this outbreak," said Williams. "For those who may be at risk for COVID-19, we encourage them to utilize this hotline or call their health care provider or local public health agency to inform them of their travel history and symptoms. They'll be instructed on how to receive care without exposing others to the possible illness."

 

Simple preventive actions that help prevent the spread of all types of respiratory viruses include:

 For more information, visit www.health.mo.gov/coronavirus or the CDC's COVID-19 website.

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Information Released by MAHC on March 4, 2020:

 

As a follow-up to my email yesterday, please find below two additional Home Care and Hospice COVID-19 resources as well as additional information from the CDC.

 

 

Two More Home Care and Hospice Resources

  1. Barbara Citarella of RBC Limited Healthcare & Management Consultants has developed a CHECK LIST with actions that agencies should be taking right now to prepare for COVID-19. The checklist helps agencies prioritize and organize activities related to an emergency preparedness plan for infectious diseases.
  2. The LHC Group, Inc. is sharing with MAHC members its POLICY and PROCEDURE for responding to COVID-19 for both staff and patients.
     

Additional CDC Information

 

The Centers for Disease Control and Prevention (CDC) is promising more information to help clinicians treat and care for patients with coronavirus.

 

"It's very important clinicians have the information they need to make the best decisions possible for their patients," Nancy Messonnier, M.D., director of the CDC's National Center for Immunization and Respiratory Diseases, said during a media call Tuesday to provide an update on the response to the virus known as COVID-19.

 

In addition to the guidance for clinicians on the CDC website, the agency will hold a call for clinicians Thursday, March 5, from 2-3 p.m. (Eastern) on what they need to know to prepare for COVID-19.

 

The Clinician Outreach and Communication Activity call is expected to attract thousands of listeners as healthcare professionals try to stay current with the ever-changing coronavirus situation. The last call, held in late January at the start of the coronavirus outbreak, had more than 10,000 listeners, Messonnier said.

 

Clinicians can sign into the call where the CDC promises information on what they can do to prepare for COVID-19, including how to identify patients suspected of having the virus, apply infection prevention and control measures, assess risks for exposures, optimize the use of personal protective equipment supplies and manage and care for patients who are hospitalized or who remain at home.

 

RELATED: As coronavirus spreads, infectious disease doctors suggest travel history be made 5th vital sign

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Information Released by MAHC on March 3, 2020:

While there is a vast amount of information available, MAHC has compiled a variety of resources for home care providers to access related to the 2019 Novel Coronavirus.

At this time, MAHC suggests that home care providers follow the Centers for Disease Control and Prevention's (CDC) guidance. As this situation is constantly evolving, we also recommend that you review the CDC's website periodically for updated information as well as the Missouri Department of Health and Senior Services website for Missouri specific information.


Novel Coronavirus Resource Information and Guidance

 

Missouri Department of Health and Senior Services: Missouri's resource page includes links to CDC and other information sites along with specific Missouri information/data.

 

Centers for Disease Control and Prevention: CDC's resource page includes what you should know about the virus, situation updates, and information for travelers, businesses, and others.

 

Home Care Specific Guidance:

Healthcare Guidance:

Location Guidance:

 

 

Centers for Medicare and Medicaid Services (CMS)

Surveyors to Enforce CDC Guidance for the 2019 Coronavirus

The Centers for Medicare & Medicaid Services (CMS) has issued a letter to surveyors that addresses infection control adherence for health care facilities related to the 2019 Novel Coronavirus (2019-nCoV), and reminds surveyors that providers must consider emerging infectious diseases in their emergency preparedness plans.

 

The letter includes interim guidance issued by the Centers for Disease Control and Prevention (CDC) for health care facility infection control procedures related to the 2019 nCoV. The CDC is currently advising adherence to Standard, Contact, and Airborne Precautions, including the use of eye protection. Health care staff should also adhere to CDC recommendations on standard hand hygiene practices, using alcohol-based hand rub/hand sanitizer as the preferred method of hand hygiene in most clinical situations. If hands are visibly soiled, wash with soap and water for at least 20 seconds. Healthcare facilities should ensure that hand hygiene supplies are readily available.

 

CDC has also developed interim guidance for staff at local and state health departments, infection prevention and control professionals, healthcare providers, and healthcare workers who are coordinating the home care and isolation of people who are confirmed to have, or being evaluated for 2019 novel coronavirus (2019-nCoV) infection.

 

Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services- OCR has issued guidance on ways that patient information may be shared so that the protections of the HIPAA Privacy Rule are not set aside during an emergency.

 

World Health Organization: On this website you can find information and guidance from WHO regarding the current outbreak of coronavirus disease (COVID-19).

 

U.S. Chamber of Commerce: The Chamber's "Understanding the Coronavirus" webinar, recorded on January 27 in partnership with CDC, discusses the impact of the virus on the private sector and what businesses should consider as they respond. 

 

U.S. Travel Association: