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Pam Kaiser

By Pam Kaiser, MSN, RN

With so many waivers and flexibilities being released by CMS in response to the COVID-19 pandemic, keeping current with those that impact your provider setting can be challenging. Sometimes those that impact you might be designed for another setting altogether!

The Centers for Medicare and Medicaid (CMS) can authorize waivers when the President declares a national emergency and the Secretary of Health and Human Services declares a public health emergency. These steps have been taken, thus enabling CMS to issue waivers.

CMS Waivers – A 4-Pronged Approach

For the current pandemic, CMS uses waivers to support a 4-pronged approach:

1. Increase hospital capacity
  • e.g., Hospital without Walls concept allows non-certified beds to be used for Medicare patients
2. Expand workforce
  • e.g., Licensed professionals can practice across state lines
3. Emphasize patients over paperwork
  • e.g., Relaxing documentation requirements like timing and delivery of discharge documents
4. Support telehealth and medicine
  • e.g., Expanding use outside of rural areas or outside medical facilities

SNF 3-Day Waiver

One waiver that impacts Skilled Nursing Facilities (SNFs) also has direct impact on Hospital systems.  Since it addresses moving residents to SNF level of care, it falls under the first prong: Increase hospital capacity.

Referred to as the SNF 3 day waiver, this waiver allows Medicare beneficiaries to access their Part A SNF benefit without having the required 3 overnights in an acute care hospital. The beneficiary still needs to have a skilled need that is medically reasonable and necessary, but no longer requires admission to the hospital to qualify.

Implications for Hospitals

What that means to hospitals is that Medicare A patients that come to the Emergency Department can be directly sent to a Medicare certified SNF and be eligible to access Medicare for their skilled nursing benefit. If a beneficiary is hospitalized overnight only, or just for a couple of days, they can also be admitted to the SNF.

As you work with your local SNFs to address this pandemic, review the current waivers and flexibilities available on the CMS Current Emergency  site for both your workplaces. Use them to improve your collaboration during these challenging times. We all do better when we work together.

Check out the video below featuring Senior Healthcare Specialist Maria Arellano explaining the 1135 (3 Day) Waiver. You can also receive emails when new resources become available by subscribing to our mailing list. 

Author:

Pam Kaiser, MSN, RN
Vice President, Clinical Resource Team, PointRight

Pam has enjoyed 27 years in the healthcare field. A second career for her, she worked her way from a certified nursing assistant through the long term care ranks to become a leader in clinical reimbursement and compliance for several large long term care providers. She has a B.A in Advertising from Michigan State University and an MSN in Community Health Nursing from the University of Southern Maine.

Filed Under: Blog

Maria Arellano

By Maria Arellano, MS, RN, RAC-CT

CMS’s rapid fire memos on COVID-19 over the last two weeks surely leave many facility staff confused and overwhelmed. Finding time to sit, read and interpret these memos may be rare so here’s what you need to know. If you’re in your survey window right now, CMS may be giving you some much needed breathing room if you do not land in one of the priority categories.

March 4 CMS Memo Suspending Non-Emergency Surveys

On March 4th, CMS released a memo suspending non-emergency surveys across the country, allowing surveyors to focus on the most serious health and safety threats, such as infections and abuse.

Effective immediately, the survey activity was limited to the following:

  • All immediate jeopardy complaints (cases that represents a situation in which entity noncompliance has placed the health and safety of recipients in its care at risk for serious injury, serious harm, serious impairment or death or harm) and allegations of abuse and neglect;
  • Complaints alleging infection control concerns, including facilities with potential COVID-19 or other respiratory illnesses;
  • Statutorily required recertification surveys (Nursing Home, Home Health, Hospice, and ICF/IID facilities);
  • Any re-visits necessary to resolve current enforcement actions;
  • Initial certifications;
  • Surveys of facilities/hospitals that have a history of infection control deficiencies at the immediate jeopardy level in the last three years;
  • Surveys of facilities/hospitals/dialysis centers that have a history of infection control deficiencies at lower levels than immediate jeopardy.

March 23 CMS Memo Revisions

On March 23rd, CMS released another memo that revised their COVID-19 survey strategy for the next 3 weeks to focus on facilities that meet the following criteria:

  • Complaint/facility-reported incident surveys triaged at IJ level, and
  • Targeted Infection Control Surveys in key states, currently CA, NY, and WA, but others may be added as cases rise.

The March 23rd memo revises the March 4th memo for the next three weeks only and allows health care providers time to implement the most recent infection control guidance from both CMS and the Centers for Disease Control and Prevention (CDC). During this three-week timeframe, state survey agencies (SSAs) and CMS surveyors will prioritize and conduct surveys (including revisit surveys) related to complaints and facility reported incidents (FRIs) that are triaged at the Immediate Jeopardy (IJ) level, for all allegations, in addition to a review with a Focused Infection Control survey.

COVID-19 Focused Survey Document

The Critical Element pathway for the COVID-19 Focused Survey was also provided. This tool offers facilities full visibility into the Focused Survey to understand CMS’s expectations for an infection prevention and control program during the COVID-19 pandemic. CMS expects facilities to use this new process, in conjunction with the latest guidance from CDC, to perform a voluntary self-assessment of their ability to prevent the transmission of COVID-19.  This document may be requested by surveyors if an onsite investigation takes place.  CMS also encourages nursing homes to voluntarily share the results of this assessment with their state or local health department Healthcare-Associated Infections (HAI) Program. Seema Verma, CMS administrator, suggested that nursing home residents and their families should ask about the results of this self-assessment to ensure the facility is safe.

5 Ways to Prepare for Potential Survey

  1. Review your survey history to assess your risk for a prioritized survey.
  • Any Immediate Jeopardy deficiencies in F880, F881, F882, or F883 on a standard or complaint survey?
  • Any recent complaints of abuse or facility reported incidents that could rise to an immediate jeopardy level?
  • Any repeat deficiencies in the last 3 surveys for infection control at a lower scope and severity?
  1. Complete the Coronavirus Disease 2019 (COVID-19) Preparedness Checklist for Nursing Homes and other Long-Term Care Settings. Document your findings and include any action plans to resolve them.
  2. Review the CMS COVID-19 Focused Survey Checklist with the full department leadership team to identify weaknesses and support your survey readiness strategy.
  3. Monitor the CDC website daily as well as the CMS Coronavirus Updates for changes.
  4. Be ready for residents, families and others to request the results of your self-assessments.

If you are at risk for a survey either by survey history or geographical location, completing these checklists and developing comprehensive action plans can go a long way in demonstrating your commitment to quality of care and safety for your residents and your proactive efforts may actually save you a deficiency or two.

Author:

Maria Arellano, MS, RN, RAC-CT
Senior Healthcare Specialist, PointRight

Maria has over 35 years’ experience as a registered nurse in the post-acute industry. Maria has served in a variety of roles directly in or supporting the long-term post-acute care sector including staff development, director of nursing and corporate consultant where she demonstrated regulatory excellence and exemplary quality outcomes. Previously she was a nursing home quality specialist with a quality improvement organization (QIO) and worked to enhance the quality of care for residents. Maria participated on CMS Technical Expert Panels as well as various committees and advisory boards throughout her career. She is focused on quality improvement, which fuels her passion for transforming data into knowledge and actionable insights.

 

Filed Under: Blog

Jennifer GrossBy Jennifer Gross, BSN, RAC-CT, CPHIMS

The COVID-19 pandemic is hitting skilled nursing facilities (SNFs) hard.  Along with the potential health impact on your residents, staff, and families, there have been several regulatory updates issued by CMS after a State of Emergency was declared on March 13th.  Here are five things that nurse assessment coordinators (NACs) should know.

New ICD-10 code for COVID-19

The effective date for the new code, which was originally planned for October 1, has been pushed up to April 1.  The details and exclusions for the new code, U07.1 COVID-19, can be found in the ICD-10-CM Tabular List of Diseases and Injuries April 1, 2020 Addenda.  As with any diagnosis, in order to code COVID-19 in Section I8000 you will need a physician’s diagnosis with supporting laboratory results.

Coding O0100M, Isolation for active infectious disease

In some cases, you may have residents with COVID-19 who meet the criteria to capture isolation on the MDS.  This will potentially capture the Extensive Services qualifier for PDPM and RUG-based Medicaid reimbursement.  However, make sure that all the criteria are met for this item (see the RAI v. 3.0 Manual on pp. O-5 and O-6).  In particular, remember that:

  • The isolation is “single-room” – cohorting with another resident who also has COVID-19 does not count.
  • The resident must remain in his or her room – all services must be brought into the isolation room.
  • If the resident needs to leave the room for a medically necessary reason, the CDC Guideline for Isolation Precautions must be followed.

Relaxation of the MDS submission requirements

As part of the Section 1135 waiver, CMS waived the MDS submission timeframe requirements in 42 CFR 483.20.  This waiver allows some breathing room for facilities that need to have all hands on deck caring for their residents with COVID-19 including the MDS team.  However, CMS hasn’t yet released any further guidance on this, nor have they specifically addressed Medicare PPS assessments.  Our recommendation: keep up to date on your MDSs if you possibly can.  Remember that the standard MDS timeframe allows 14 days to complete the MDS after the Assessment Reference Date, and another 14 days after the MDS completion date in Z0500B or the care plan completion date in V0200C2 (RAI v. 3.0 Manual, p. 5-3).  Use that time, and only opt for the waived timeframe if you absolutely need it to stay in compliance.

SNF Quality Reporting Program (QRP) reporting requirement exceptions/extensions

CMS has announced that the upcoming data submission deadlines for Q4 2019, as well as data for Q1 and Q2 2020, will be optional.  This goes along with the MDS submission waiver above, as well as submitting corrections to MDSs that appear in your “dash report.”  Again, our recommendation is to stay on track if you are able to, and make sure that the MDSs you submit are as complete as possible so that any future reporting is accurate.

Infection control also applies to the MDS process

As you are interacting with your residents doing your assessment – resident interviews, observation for swallowing problems, balance assessment etc. – be sure to maintain transmission-based precautions.  Consider your resident interview process; are you able to maintain six feet of distance from the resident and still be able to communicate?  Assess whether personal protective equipment (PPE) is needed, and refer to your facility’s infection control and PPE conservation policies to make sure that your residents (and you) are protected when you are working with them.

Author: 

Jennifer Gross,  BSN, RAC-CT, CPHIMS
Senior Healthcare Specialist, PointRight

Jennifer Gross’s experience in the nursing field includes work in psychiatric rehab and in long term care as a staff nurse, MDS coordinator, and as a consultant. Her role at PointRight is to support our clients in understanding the intricacies of the MDS, enabling them to maximize quality of care, identify residents at risk, and prevent decline.

 

Filed Under: Blog

Thank you for taking care of the most vulnerable among us – our parents, our grandparents and many other loved ones in all our families. We are so incredibly fortunate that we can count on you and your team to be there in this time of turmoil and uncertainty.

The PointRight team is leveraging our remote working capabilities to continue to support and provide necessary services to you and your team.  Our support procedures and our staff’s availability have not changed.

PointRight is here to stand with you. Let me share what we are doing.
  • Our advanced technology / infrastructure is providing ongoing and uninterrupted service to our clients.
  • For quick reference, we’re publishing blogs from our clinical experts to help SNFs, hospitals, ACOs and REITs focus
    on relevant best practices at this time –
  • Our website’s Industry Insights section offers aggregated COVID-19 FAQs from industry leaders.
  • Our deeply experienced Clinical Resource Team is here to help answer questions related to the 1135 Waiver of
    MDS submissions deadlines and its potential impact on your operations.
  • To help provide future guidance, our data scientists are leveraging our advanced analytic capabilities to forecast survey
    deficiency risks that SNFs in different regions, with different specialties, will face as the healthcare system and its
    regulators resume more usual operations.

The PointRight team is proud to support your organization. If you have any questions, please feel free to contact us. You can always reach us at support@pointright.com or reach out to your Account Manager or Business Development Executive.

 

Best regards,

Steven Scott
President & Chief Executive Officer

Filed Under: Blog

Hospitals and REITs must proactively communicate and perform their due diligence to manage risk and support partners and stakeholders.

Maria Arellano
Maria Arellano, RN, MS, Senior Healthcare Specialist

By Maria Arellano, MS, RN

Skilled Nursing facilities (SNFs) find themselves under the magnifying glass as the first cases of Coronavirus COVID-19 appeared within the walls of a Washington SNF. It’s not surprising as these facilities provide services to individuals most vulnerable to the virus, and if SNF patients are infected, the potential for increased rehospitalizations is high. The Centers for Medicare & Medicaid Services (CMS) released a memo last week revealing their priorities for nursing facility inspections effective immediately. The memo directed the states to suspend non-emergency inspections across the country, allowing inspectors to turn their attention to the most serious health and safety issues including infectious diseases and abuse.

Impact to SNF Survey Activity

For now, SNF survey activity is limited to the following (in Priority Order):

  • All immediate jeopardy complaints (cases that represents a situation in which entity noncompliance has placed the health and safety of recipients in its care at risk for serious injury, serious harm, serious impairment or death or harm) and allegations of abuse and neglect;
  • Complaints alleging infection control concerns, including facilities with potential COVID-19 or other respiratory illnesses;
  • Statutorily required recertification surveys (Nursing Home, Home Health, Hospice, and ICF/IID facilities);
  • Any re-visits necessary to resolve current enforcement actions;
  • Initial certifications;
  • Surveys of facilities/hospitals that have a history of infection control deficiencies at the immediate jeopardy level in the last three years;
  • Surveys of facilities/hospitals/dialysis centers that have a history of infection control deficiencies at lower levels than immediate jeopardy.

How can you mitigate risks in your network of SNFs?

Two simple actions can go a long way in reducing your risk of increased rehospitalizations.

Proactively Communicate

Scheduling a proactive (possibly remote?) meeting with SNF leadership can go a long way in reducing the risk of exposing the residents to the virus as well as potentially avoiding additional inspection citations and public scrutiny. Is the facility following CDC recommendations? Are they staying abreast of conditions in their communities and ensuring staff vigilance and adherence to strict infection prevention practices? All facilities should have an Infection Preventionist on staff and lead the aggressive efforts to keep the virus out of the facility. Working with your partners to prevent the spread of the virus in the community can also improve communication and learning opportunities for all.

Do Your Homework

Take time to ask the SNFs about their survey history over the last 3 years. Do they fall into any of the priority categories for survey?  F880 is the federal tag for Infection Prevention and Control and includes a very comprehensive list of requirements within the regulation. Has the facility been cited in the last 3 years for F880? What was the scope and severity of the citation – isolated, pattern or widespread? Is this a repeat deficiency from a prior year? Repeat deficiencies can certainly place a facility at higher risk to be monitored more closely.

Be Prepared

Given the serious threat to the health of nursing facility residents and the significant media attention surrounding the virus, you can be sure the states will approach their inspections of the prioritized groups with laser focus and intensity.  CMS’ memo clearly indicated that these actions reiterate their commitment to taking critical steps to ensure America’s health care facilities are prepared to respond to the threat of the Coronavirus (COVID-19).

Latest COVID-19 updates from the CDC, WHO and more…

Author:

Maria Arellano, MS, RN
Senior Healthcare Specialist, PointRight

Maria has over 35 years’ experience as a registered nurse in the post-acute industry. Maria has served in a variety of roles directly in or supporting the long-term post-acute care sector including staff development, director of nursing and corporate consultant where she demonstrated regulatory excellence and exemplary quality outcomes. Previously she was a nursing home quality specialist with a quality improvement organization (QIO) and worked to enhance the quality of care for residents. Maria participated on CMS Technical Expert Panels as well as various committees and advisory boards throughout her career. She is focused on quality improvement, which fuels her passion for transforming data into knowledge and actionable insights.

Filed Under: Blog

Jennifer GrossBy Jennifer Gross, BSN, RAC-CT, CPHIMS

What do top-level athletes, no matter what sport they play, have in common?  They never stop drilling the fundamentals of the game.  As COVID-19 (a.k.a. coronavirus) continues to spread into our most vulnerable populations, skilled nursing facilities (SNFs) are reeling from the impact.  While the risk for survey citations is apparent (see CMS’ latest memo, revised on March 9th), SNFs’ top priority is protecting their residents, staff, and communities. 

As you put your COVID-19 plan into practice, focus on these fundamentals (but wash your hands first):

Basic Infection Control Principles

Your SNF already has an infection prevention and control policy and procedure in place; as you prepared for the Phase 3 Requirements of Participation this policy would have had a thorough revision. If this policy hasn’t yet been put to the test, now is the time.  The training and leadership of your Infection Preventionist will pay off – for example, having the appropriate precautions in place for the type of contagion.  The CDC guidance for COVID-19 calls for standard, contact, and airborne precautions.

Assess Your Resources and Supplies

Part of the effect of the virus’ spread is the impact on the supply chain. Evaluate your access to key supplies – such as gloves, masks, and other personal protective equipment (PPE).  Coordinate with your local referring hospital on an agreement to use them as a go-to resource if you have a critical shortage.  Also know how to get in touch with your local health department – not only for updates on local infection rates, but also for assistance with accessing outside supply sources.

Staff Education and Preparation

Infection control is already part of your annual mandatory staff training. Make sure that this program is up to date with the latest standards of infection prevention and control.  Ensure that all your staff are trained – this means you, Business Office Managers!  For direct care staff, make sure that you have a return demonstration of handwashing, donning and doffing PPE, and handling laundry and disposables.  This is a team where every single player has an important role.

Communicate, Communicate, Communicate

With every day bringing more serious news reports about the spread of COVID-19, your residents and their families are looking to you to keep them in the loop. Use your regular newsletter/e-news to provide the latest updates.  Offer conference calls or webinars to reach out to far-away family members. Make sure that your visitation plan is clear, posted in easy-to-understand language, and enforced consistently.  If you need to limit outside visitors due to active infection in the area, reach out to the families directly rather than relying on a sign on the door.  Most of all, be available for questions…the residents and families are part of your team, too! 

More COVID-19 (Coronavirus) Resources

Author: 

Jennifer Gross,  BSN, RAC-CT, CPHIMS
Senior Healthcare Specialist, PointRight

Jennifer Gross’s experience in the nursing field includes work in psychiatric rehab and in long term care as a staff nurse, MDS coordinator, and as a consultant. Her role at PointRight is to support our clients in understanding the intricacies of the MDS, enabling them to maximize quality of care, identify residents at risk, and prevent decline.

Filed Under: Blog

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