INTRODUCTION

NRHP has put together this resource toolkit to assist Nevada Critical Access Hospitals (CAHs) during the coronavirus (COVID-19) outbreak.

Guidance from the Centers for Disease Control and Prevention (CDC) and the state and local Departments of Public Health supersede the information in this toolkit. 

For the most up-to-date information and guidance, please visit the following websites as this is a rapidly evolving subject:

Click here to view a thank you message from Nevada Congressman Mark Amodei to the Humboldt County healthcare workers and first responders. 

Please contact Becky Bayley at (775) 830-7458 with any questions regarding this toolkit.

STATE AND LOCAL HEALTH AUTHORITY CONTACTS

Facilities should immediately call their local or state health authority if they have a suspected COVID-19 case. Contact numbers for all Nevada CAHs are listed below.

Health Authority Contact Information Facilities
Carson City Health and Human Services (775) 887-2190 Carson Valley Medical Center
South Lyon Medical Center
Southern Nevada Health District (702) 759-1300 Boulder City Hospital
Washoe County Health District (775) 328-2447 Incline Village Community Hospital
Nevada Division of Public and Behavioral Health (775) 684-5911
(M-F 8am-5pm)


(775) 400-0333
(after hours epi-on-call)

Banner Churchill Community Hospital
Battle Mountain General Hospital
Desert View Hospital
Grover C. Dils Medical Center
Humboldt General Hospital
Mt. Grant General Hospital
Pershing General Hospital
William Bee Ririe Hospital

TOOLKIT MENU

Identify – Isolate – Inform

Infection Control

Evaluation & Testing

Preparedness Checklists

Training & Education

PPE Supplies

Healthcare Personnel

Patient Communications

Visitor Restrictions

Finance & Operations

Funding Opportunities

Community Collaboration

Human Resources

Surge Capacity

Telemedicine

Long Term Care

EMS

Reporting Requirements

EMTALA

HIPAA / Privacy

Regulatory Environment

IDENTIFY-ISOLATE-INFORM

The Identify-Isolate-Inform (3I) Tool, originally conceived for the initial detection and management of Ebola virus. Although the progression of the COVID-19 pandemic has made some pieces of the tool, such as travel history, less relevant, it can still be adapted for any emerging infectious disease, including the 2019 coronavirus. View the original algorithm here: https://www.cdc.gov/vhf/ebola/pdf/ambulatory-care-evaluation-of-patients-with-possible-ebola.pdf


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INFECTION CONTROL

Clinicians should immediately implement recommended infection prevention and control practices if a patient is suspected of having COVID-19. Hospitals should refer to the following CDC website for the most current recommendations:

https://www.cdc.gov/coronavirus/2019-ncov/hcp/infection-control.html

The following interim guidance has been updated based on currently available information about COVID-19 and the current situation in the United States. As healthcare facilities begin to relax restrictions on healthcare services provided to patients (e.g., restarting elective procedures), in accordance with guidance from local and state officials, there are precautions that should remain in place as a part of the ongoing response to the COVID-19 pandemic. CDC recommendations have been reorganized into the following sections:

  • Recommended infection prevention and control (IPC) practices for routine healthcare delivery during the pandemic
  • Recommended IPC practices when caring for a patient with suspected or confirmed SARS-CoV-2 infection

https://www.cdc.gov/coronavirus/2019-ncov/infection-control/control-recommendations.html

Guidance on When to DISCONTINUE Isolation and Transmission-Based Precautions 

The following interim guidance should be followed concerning the discontinuation of transmission-based precautions and disposition of patients with COVID-19 in healthcare settings:

https://www.cdc.gov/coronavirus/2019-ncov/hcp/disposition-hospitalized-patients.html

RESOURCE: DPBH Discontinuation of Transmission-Based Precautions and Disposition of Patients with COVID-19 in Healthcare Settings 05/03/20

RESOURCE: DPBH Interim Guidelines for Discontinuation of In-Home Isolation and Transmission-Based Precautions among Hospitalized Patients with COVID-19 Technical Bulletin 03-17-20

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EVALUATION AND TESTING

Hospitals should refer to the following CDC website for the most current guidance on SARS-CoV-2 testing:

https://www.cdc.gov/coronavirus/2019-ncov/hcp/testing.html

TESTING SUPPLIES/COLLECTION KITS

>>>UPDATE AS OF MAY 12, 2020: Requests for All COVID-19 Testing Supplies and PPE Must Go Through County Emergency Manager

To obtain test kits for collecting specimens going to the Nevada State Public Health Laboratory (NSPHL) or the Southern Nevada Public Health Laboratory (SNPHL), or to request additional personal protective equipment (PPE), it is recommended that you place your request for a one or two week supply through your local County Emergency Manager. Hospitals should be able to obtain as many collection kits as they are sending in on a “replacement basis”, as there is still a limited supply of collection kits and materials.

RESOURCE: State of Nevada NDEM/SEOC Resource Request Form

RESOURCE: Resource Request Process

RESOURCE: Resource Request Flow

>>>UPDATE AS OF MARCH 27, 2020: COVID-19 Testing Supplies Available from the Nevada State Public Health Laboratory

The Nevada State Public Health Laboratory (NSPHL) is manufacturing collection kits which can be ordered via their External Supply Order Form. If facilities cannot pick up the collection kits, they may use the “ship to” section of the form.

>>>UPDATE AS OF MARCH 12, 2020:

The FDA has established a 24/7 hotline for laboratories that are in need of additional testing supplies. Facilities may call 1-888-INFO-FDA (1-888-463-6332). Hospitals should also notify their public health authority:

  • Carson City Health and Human Services: (775) 887-2190
  • Southern Nevada Health District: (702) 759-1300
  • Washoe County Health District: (775) 328-2447
  • Nevada Division of Public and Behavioral Health: (775) 684-5911 or (775) 400-0333 after hours

TESTING CRITERIA

>>>UPDATE AS OF 5/5/20: EXPANDED TESTING CRITERIA

Nevada health officials are advising the health care community that testing just symptomatic patients may not be sufficient to prevent further transmission of COVID-19. Testing expansion is urgently required to determine the impact of asymptomatic cases on viral spread.

Current symptom-based screening strategies seem to be inadequate to identify or early detect all COVID-19 cases to prevent viral spread in the community and the transmission of infection within skilled nursing homes and other residential facilities. Increasing testing availability will allow clinicians to consider testing for wider groups including mildly symptomatic, asymptomatic, and pre-symptomatic patients. To early identify more COVID-19 cases, testing should be extended to individuals with and without symptoms. Focused activities should be implemented to reduce and ultimately prevent further transmission, including testing of asymptomatic high-risk vulnerable individuals and those who could have been exposed to COVID-19 cases.

RESOURCE: DPBH Technical Bulletin 05/05/20: Expansion of COVID-19 Testing Criteria

>>>UPDATE AS OF APRIL 20: EXPANDED TESTING CRITERIA

DPBH has issued updated testing criteria for COVID-19 in order to expand laboratory testing to include all patients exhibiting symptoms consistent with COVID-19 infection and ensure a more robust approach to rapid infection control and containment within our state. See the Technical Bulletin below for the updated testing criteria:

RESOURCE: DPBH Technical Bulletin – Updated Testing Criteria for COVID-19 04/20/20

Recommendations for testing prioritization from Nevada DHHS can be found in the information sheet below:

RESOURCE: NV Health Response COVID-19 Testing Information for Health Care Providers

>>>INITIAL TESTING CRITERIAL GUIDANCE:

RESOURCE: DPBH Interim Testing Criteria Technical Bulletin 03-20-20

RESOURCE: DPBH Criteria for Testing (COVID-19) Form
*Note: This form is NOT mandated by DPBH. It is meant to assist in the clinician’s decision making process only. 

NOTIFICATION OF STATE

Health care providers should immediately notify their local/state health department in the event of a person under investigation (PUI) for COVID-19.

For rural hospitals under the jurisdiction of DPBH, PUI numbers are required regardless of laboratory being used, but the provider should not delay care or testing to obtain a PUI number. Facilities should have blocks of PUI numbers to assign to PUIs and should not need to contact DPBH to just to obtain PUI numbers at this time. 

Note: In order to allow for more accurate reporting of testng and results by county, facilities should include the patient’s physical address along with the county of residence on every lab requisition form for COVID-19 testing in addition to other demographic information required, regardless of which lab is utilized.

For more information on the reporting requirements for hospitals, please visit the Reporting Requirements section of this website.

SPECIMEN COLLECTION

For more information on specimen collection kits/testing supplies, please visit the Inventory and Supplies section of this webpage. 

Laboratory Contact Information
Nevada State Public Health Laboratory https://med.unr.edu/nsphl/emergency/covid19
(775) 688-1335 (M-F 8:00am to 5:00pm)
(775) 823-1150 (after hours and weekends)
Southern Nevada Public Health Laboratory https://www.southernnevadahealthdistrict.org/programs/southern-nevada-public-health-laboratory/
(702) 759-1000
Quest Diagnostics https://www.questdiagnostics.com/home/Covid-19/
(866) 404-1550
LabCorp https://www.labcorp.com/information-labcorp-about-coronavirus-disease-2019-covid-19

PACKING, SHIPPING AND TRANSPORT

Specimens must be packaged, shipped, and transported according to the specifications of each testing facility/courier. Please contact the state lab or reference lab via the contact information listed above for the most current instructions.

https://www.cdc.gov/coronavirus/2019-nCoV/lab/index.html

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TRAINING AND EDUCATION

Refer to the CDC for up-to-date training for Healthcare Professionals:

https://www.cdc.gov/coronavirus/2019-ncov/hcp/training.html

Healthcare professionals (HCPs) should have job-specific training on all policies and procedures regarding COVID-19, including:


Note: Environmental services personnel MUST have proper training, especially in regard to disinfection practices of high touch surfaces and observing dwell time!

RESOURCE: CDC Cleaning and Disinfecting Your Facility


The following materials are provided to assist CAHs with education of staff members on various aspects of COVID-19:

RESOURCE: WHO “The COVID-19 Risk Communication Package for Healthcare Facilities

RESOURCE: Sample COVID-19 Poster (courtesy of Renown)

RESOURCE: Use of PPE Infographic 03/30/20

Refer to the CDC for up-to-date information on the use of personal protective equipment (PPE), including donning and doffing illustrations and videos:

https://www.cdc.gov/coronavirus/2019-ncov/hcp/using-ppe.html

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PERSONAL PROTECTIVE EQUIPMENT (PPE) SUPPLIES

UPDATE AS OF MAY 12, 2020:

Requests for All COVID-19 Testing Supplies and PPE Must Go Through County Emergency Manager

To obtain test kits for collecting specimens going to the Nevada State Public Health Laboratory (NSPHL) or the Southern Nevada Public Health Laboratory (SNPHL), or to request additional personal protective equipment (PPE), it is recommended that you place your request for a one or two week supply through your local County Emergency Manager. Hospitals should be able to obtain as many collection kits as they are sending in on a “replacement basis”, as there is still a limited supply of collection kits and materials.

RESOURCE: State of Nevada NDEM/SEOC Resource Request Form

RESOURCE: Resource Request Process

RESOURCE: Resource Request Flow

Battelle N95 Decontamination

The Nevada Division of Emergency Management, Division of Public and Behavioral Health, and the Federal Emergency Management Agency have coordinated the use of a Battelle Sterilization System to sterilize N-95 masks for Nevada’s first responders and health care workers. Sterilized masks can be reused up to 20 times, and sterilization will be done at no charge to health facilities or the state.

Health facilities and first responders are encouraged to immediately save their used N-95 respirators and not dispose of them; the Battelle sterilization will begin the week of May 10. Nevada received one Battelle unit and it is set up in Henderson. Facilities located within two hours’ drive will be picked up; all others can be shipped to Battelle and sent back the same way so this service will be accessible to the entire state. All shipping costs will be covered by Battelle with no cost to facilities.

Facilities that want to participate in the Battelle sterilization must submit contact information for the person within the facility who is coordinating the collection of the equipment and will receive it upon its return. Send the individual’s name and email address to NDEMoperations@gmail.com or to mnfriend@dps.state.nv.us.

https://www.battelle.org/decon

RESOURCE: Battelle Decontamination System Fact Sheet for HCP

RESOURCE: FDA Investigating Decontamination and Reuse of Respirators in Public Health Emergencies

RESOURCE: Guide for Identifying FDA EUA Authorized N95 Respirators for Battelle CCDS™ Processing – April 24, 2020

3D Printed Protective Face Shields from UNR!

NRHP would like to thank the many people at the University of Nevada, Reno who came together to help identify solutions to the PPE shortage faced by many hospitals and healthcare workers in Nevada: Nick Crowl from the University Libraries’ DeLaMare Science and Engineering Library along with Daniel Smith from the Innevation Center, several faculty members from the Computer Science and Engineering Department and The Department of Art Fabrication Lab. The result was a 3D printed protective face shield which can be sanitized and reused. Many of these face shields have already been delivered to NRHP member hospitals across Nevada and put to use!

See more about the work that the University of Nevada, Reno is doing to meet PPE demands (and donate to the cause!) here: https://unr.scalefunder.com/cfund/project/20780.

UPDATE AS OF APRIL 3, 2020:

New guidance for alternative, improvised, and homemade facemasks have been put into place while Nevada’s Crisis Standards of Care (CSC) Plan is in effect. It is still recommended that every effort should be made to obtain FDA regulated facemasks and to comply with the CDC’s “Strategies to Optimize the Supply of PPE”. However, the Governor’s COVID-19 Medical Advisory Team is recommending the immediate use of source control alternatives, such as improvised or homemade masks for everyone under certain circumstances.

RESOURCE: DPBH Technical Bulletin re: Interim Guidance on Alternative, Improvised, and Homemade Facemasks 04/03/20 

UPDATE AS OF MARCH 17, 2020:

The Nevada State Public Health Preparedness (PHP) Program submitted a request for Personal Protective Equipment (PPE) to the U.S. Department of Health and Human Services, Assistant Secretary for Preparedness and Response (HHS/ASPR); however, PHP did not receive near what was requested.

Hospitals are asked to NOT contact their local emergency manager, or the Division of Emergency Management, or PHP directly for an update on the status of the PPE request. PHP staff are working with each local health authority to implement a regional delivery system (RDS) and a single regional drop-off location for each LHA to then deliver to those front-line first responders in most critical need in each jurisdiction in order to get the supplies out as expeditiously as possible. PHP will also be distributing to the rural counties, mainly rural hospital facilities, due to the limited supply.

Local emergency managers have submitted all resource requests for PPE that have been completed on the proper resource requesting form with all information of the requestor completed, to Division of Emergency Management (DEM) for processing. Only resource requests for PPE and other resources following this procedure will be accepted:

  1. Enter the detailed information on the attached Resource Request form outlining your request and contact information;
  2. Email completed Resource Request form to your local county emergency manager, who will then route to DEM for processing.

SURGE PREPAREDNESS

CAHs should review their inventory and secure any additional supplies that may be needed, especially to prepare for a possible surge of COVID-19 patients.

  • Are items disposable or reusable?
  • Have all staff done N95 fit testing?
  • How can N95s be used during shortages?
  • How do you properly clean and care for PAPRs?
  • Have PAPR batteries and filters been maintained?
  • How do you properly clean and care for goggles and face shields?
  • Are items being stored according to manufacturer directions?
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HEALTHCARE PERSONNEL

Caring for Your Healthcare Personnel

Protecting healthcare personnel (HCP) should be a priority for every CAH. In addition to proper training and education and ensuring adequate supply of necessary PPE, facilities should actively monitor HCP caring for possible COVID-19 patients. Staff interacting with persons under investigation (PUIs) should be required to document their daily interaction on a Room Entry Log or other tracking method.


HCP who have signs and symptoms of a respiratory infection should not report to work. Any staff that develop signs and symptoms of a respiratory infection while on the job should:

  1. Immediately stop work, put on a facemask, and go home to self-isolate;
  2. Inform the hospital’s Infection Preventionist, and include information on individuals, equipment, and locations the person came into contact with; and
  3. Contact and follow the local health department recommendations for next steps (e.g., testing, locations for treatment, etc.)

Refer to the CDC guidance for exposures that might warrant restricting asymptomatic HCP from reporting to work:

https://www.cdc.gov/coronavirus/2019-ncov/hcp/guidance-risk-assesment-hcp.html

Refer to the CDC guidance for return to work for HCP with suspected or confirmed COVID-19:

https://www.cdc.gov/coronavirus/2019-ncov/hcp/return-to-work.html

Refer to the CDC guidance for how HCP can cope with stress and build resilience during the pandemic:

https://www.cdc.gov/coronavirus/2019-ncov/community/mental-health-healthcare.html

Refer to the OSHA guidance for how standards apply to protecting workers from COVID-19:

https://www.osha.gov/SLTC/covid-19/

Refer to the CDC guidance for strategies to mitigate healthcare personnel staffing shortages here:

https://www.cdc.gov/coronavirus/2019-ncov/hcp/mitigating-staff-shortages.html


DPBH has provided a tracking form for asymptomatic HCP potentially exposed to COVID-19. Facilities should call their public health authority for guidance in completing this form and assessing the HCP; however, the form is not mandatory at this time.

The following materials are provided to assist CAHs with managing the health, safety and welfare of staff during the current outbreak of COVID-19:

RESOURCE: COVID-19 Employee Screening at Entrance Template

RESOURCE: DPBH Technical Bulletin 04/01/20 re: Guidance for Public Health Management of HCP with Potential Exposure to Patients with COVID-19 in Healthcare Settings

RESOURCE: DPBH Interim Tracking Form for Asymptomatic HCP Potentially Exposed

RESOURCE: WHO Health Workers Exposure Risk Assessment and Management in the Context of COVID-19 Virus

RESOURCE: OSHA Temporary Enforcement Guidance – Healthcare Respiratory Annual Fit-Testing for N95 Filtering Facepieces During the COVID-19 Outbreak

RESOURCE: FDA Important Information on the Use of Serological (Antibody) Tests for COVID-19 – Letter to Health Care Providers 04/17/20

New Guidance as of 05/03/20

Health facilities with patients/residents or staff who have tested positive for or show symptoms of COVID-19 are advised to follow revised guidelines when deciding to discontinue precautions (including isolation), discharge the patient or allow the employee to return to work.

Facilities can use either a symptom-based, time-based or test-based strategy for these decisions. Under the symptom-based strategy, the guidelines for discontinuing isolation and other precautions or for allowing an employee to return to work are:

  • At least 3 days (72 hours) have passed since recovery defined as resolution of fever without the use of fever-reducing medications and improvement in respiratory symptoms (e.g., cough, shortness of breath); and,
  • At least 10 days have passed since symptoms first appeared (prior guidance was 7 days).

The time-based guidelines state that at least 10 days must have passed since the date of the individual’s first positive COVID-19 diagnostic test assuming they have not subsequently developed symptoms since their positive test. If the patient/resident or staff member develops symptoms, then the symptom-based or test-based strategy should be used. Note, because symptoms cannot be used to gauge where these individuals are in the course of their illness, it is possible that the duration of viral shedding could be longer or shorter than 10 days after their first positive test.

RESOURCE: DPBH Criteria for Return to Work for Healthcare Personnel with COVID-19 05/03/20

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PATIENT COMMUNICATIONS

Signage and Patient Education

Appropriate signage should be placed at all entrances instructing patients to clean their hands, put on a facemask, and contact a hospital representative (per hospital policy) if they have certain symptoms and exposure history (per current guidance).


In addition, hospitals should supply patients with relevant information regarding COVID-19, including how to prevent the spread of the disease at home and in the community. Consider posting information on websites, social media, in newspapers, etc. More information on this can be found here:

https://www.cdc.gov/coronavirus/2019-ncov/about/steps-when-sick.html

Note: If patients are showing symptoms of respiratory illness but do not require further care by the hospital, they should be encouraged to self-isolate until signs and symptoms subside. Should the patient become a person under investigation (PUI) as determined by the local health authority, it would then be the responsibility of the State to monitor the isolation of the patient.


Example facility posters and patient educational flyers are included in this Toolkit; however, facilities are encouraged to create their own posters and flyers based on the most recent guidelines and the facility’s location and capabilities.

RESOURCE: DPBH COVID-19 Prevention Tips

RESOURCE: Washoe County Health District COVID-19 Fact Sheet

RESOURCE: Southern Nevada Health District COVID-19 Fact Sheet

RESOURCE: APIC Coronavirus Disease Fact Sheet

RESOURCE: The President’s Coronavirus Guidelines for America: 15 Days to Slow the Spread


Patient Financial Assistance

The PenFed Foundation COVID-19 Emergency Financial Relief Program was created to provide financial assistance to all Veterans, active military service members, and those currently serving in the Reserves and the National Guard who are experiencing a financial setback due to the negative economic effects of the COVID-19 pandemic. The grant amount will support 1 month of payment up to $1500 in the following areas:

  • Rent
  • Mortgage
  • Auto Loan/Lease
  • Utilities (Electric, Water, Heat)

*All checks will be sent directly to the creditor or landlord after the grant is approved. The Foundation can only support one emergency financial request per household.

Link to Apply:  https://penfedfoundation.org/apply-for-assistance/coronavirus-emergency-financial-assistance/

What will be needed:

  • DD214 or LES
  • A bill or statement for the requested expense
  • An explanation of how the financial setback is related to the COVID-19 pandemic (for example, loss of job due to quarantine and/or public health policies)

To be eligible for this program you must be in one of the following categories:

  • A Veteran that has been honorably discharged
  • A current active-duty service member
  • Currently active in the Reserves
  • Currently active in the National Guard

Behavioral Health Resources

RESOURCE: COVID-19 and Your Mental Health (English | Spanish)

RESOURCE: ASPR COVID-19 Behavioral Health Resources


Miscellaneous Resources for Patients

RESOURCE: Nevada 211 COVID-19/Coronavirus Emergency Resources

RESOURCE: Nevada CAN: Nevada COVID-19 Aging Network 

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VISITOR RESTRICTIONS

Hospitals should have heightened policies regarding visitors during the COVID-19 outbreak, especially in regard to vulnerable Skilled Nursing Facility residents.

Considerations depending on hospital capabilities include:

  • Restricting visitation to all or certain areas of the acute hospital/SNF

  • Restricting visitation hours

  • Restricting family and friends that accompany patients to the ER

  • Restricting visitors of specific ages, e.g., those under the age of 12

  • Restricting visitors based on signs and symptoms of illness

Note: Facilities should always indicate that anyone showing signs and symptoms of illness is entitled to a Medical Screening Examination and will not be turned away for medically necessary care.

Consider posting information on websites, social media, in newspapers, etc.

Finally, consider cancelling any events or activities that include members of the public and discontinuing volunteer services during the COVID-19 outbreak.

RESOURCE: Sample Visitor Screening Tool (Massachusetts General)

RESOURCE: DPBH Technical Bulletin 03/30/20 re: Limitations on Visitors

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FINANCE AND OPERATIONS

MEDICARE BILLING & PAYMENTS

Medicare Accelerated and Advanced Payments

As of April 26, CMS has announced that it is reevaluating the amounts that will be paid under its Accelerated Payment Program and suspending its Advance Payment Program to Part B suppliers effective immediately. Funding will continue to be available to hospitals and other healthcare providers on the front lines of the coronavirus response primarily from the Provider Relief Fund (see the Funding Opportunities section of this webpage for more information).

Repayment: Critical Access Hospitals (CAH) have up to one year from the date the accelerated payment was made to repay the balance.

Medicare Emergency Declaration Q&A for CAHs (Based on 1135 Waiver):

A: During the public health emergency period, and depending upon specific circumstances, CMS may waive both the limit of 25 inpatient beds and the 96-hour length of stay (LOS) limitation. If a waiver is made, then evacuees to a CAH operating under such waiver would not be counted toward the determination of the 25-bed limit or considered for the 96-hour average length of stay limit if this result is clearly identified as relating to the emergency. CAHs must clearly indicate in the medical record where an admission is made or length of stay extended to meet the demands of the emergency and must also annotate all Medicare fee-for-service claims for such admissions or length of-stay extensions with the “DR” condition code or the “CR” modifier, as applicable, for the period that the CAH remains affected by the emergency. 1135P-2

RESOURCE Medicare FFS Emergency Q&As with an 1135 Waiver

A: HHS is unable to implement specific 1135 waivers in anticipation of an actual need.  Rather, once the need arises, a waiver may be granted. The waiver can be retroactive to the date the need actually arose (i.e., back to the beginning of the waiver period).

RESOURCE Medicare FFS Emergency Q&As with an 1135 Waiver

A: CAHs already have the capability of having extra furniture as long as it is clearly in storage and is not staffed and ready for use. The CAH bed limit is statutory and would require either a statutory change or a section 1135(b) waiver to authorize any exceptions. However, under normal circumstances, CMS counts as part of the 25-bed limit any rooms/spaces that are equipped and clearly ready to be used by simply rolling a “stored” bed into that space. There is a difference between having warehoused beds that provide the ability to add surge capacity during a declared emergency and having beds that can be readily used whenever the CAH wishes to exceed the 25 bed limit. In a clear emergency situation, CMS would notify providers of the extent to which beds could be moved from storage and readied for use (and not counted). P-2

RESOURCE: Consolidated Medicare FFS Emergency Q&As without an 1135 Waiver

A: No. A CAH will receive 101 percent of reasonable costs for all inpatient services furnished by the CAH (other than services of distinct part units) irrespective of whether the patient was discharged from a hospital in an emergency area and then admitted to the CAH or transferred from that hospital.

RESOURCE: Consolidated Medicare FFS Emergency Q&As without an 1135 Waiver

MEDICAID BILLING & PAYMENTS

Medicaid Q&A for CAHs:

A: Yes, the Centers for Medicare and Medicaid Services (CMS) and the American Medical Association (AMA) have created two new Healthcare Common Procedure Coding System (HCPCS) codes and one new Current Procedural Terminology (CPT) code for outpatient hospitals and laboratories to bill for testing. The new HCPCS codes are U0001 and U0002, and the CPT code is 87635. The ICD-10 diagnosis code for COVID-19 is U07.1.

Nevada Medicaid is currently in the process of completing system updates to allow for reimbursement of these tests. At this time there is no implementation date determined, however, any claims submitted with HCPCS/CPT codes U0001, U0002, or 87635 will be suspended until system configurations are completed, at which time claims will be released for reimbursement.

A: CMS has released reimbursement methodology for the COVID-19 laboratory tests. Nevada Medicaid reimburses laboratory procedures at 50% of the rate allowed by the 2014 Medicare Clinical Diagnostic Laboratory Fee Schedule.

MEDICARE PROVIDER ENROLLMENT

MEDICAID PROVIDER ENROLLMENT

  • Provider revalidations with due dates from March 16, 2020 through May 16, 2020 have been extended by 60 days.
  • Providers licensed in another state who are not licensed in NV must submit an enrollment application with NV Medicaid.
  • Fingerprint-based Criminal Background Checks (FCBC) are temporarily postponed.
  • Site visits are temporarily postponed.

RESOURCE: Medicaid Update on Provider Enrollment 03/25/20

CODING

For possible exposure to COVID-19 with the disease ruled out, report Z03.818 (Encounter for observation for suspected exposure to other biological agents ruled out). For actual exposure to COVID-19, report Z20.828 (Contact with and (suspected) exposure to other viral communicable diseases.)

RESOURCE: ArchProCoding COVID-19 Training


New Code: U07.1 COVID-19

RESOURCE: ICD-10-CM Tabular List of Diseases and Injuries April 1, 2020 Addenda


Note: For cases where there is a concern about a possible exposure to COVID-19, but this is ruled out after evaluation, it would be appropriate to assign the code Z03.818, Encounter for observation for suspected exposure to other biological agents ruled out. For cases where there is an actual exposure to someone who is confirmed to have COVID-19, it would be appropriate to assign the code Z20.828, Contact with and (suspected) exposure to other viral communicable diseases. 

RESOURCE: ICD-10-CM Official Coding Guidelines – Supplement Coding encounters related to COVID-19 Coronavirus Outbreak February 20, 2020 

RESOURCE: International Classification of Diseases, Tenth Revision, Clinical Modification (ICD-10-CM)


Medicare Administrative Contractor (MAC) COVID-19 Test Pricing March 12, 2020:

RESOURCE: MAC COVID-19 Test Pricing


CMS Develops Additional Code for Coronavirus Lab Tests

“CMS developed the first HCPCS code (U0001) to bill for tests and track new cases of the virus. This code is used specifically for CDC testing laboratories to test patients for SARS-CoV-2. The second HCPCS billing code (U0002) allows laboratories to bill for non-CDC laboratory tests for SARS-CoV-2/2019-nCoV (COVID-19). The Medicare claims processing systems will be able to accept these codes starting on April 1, 2020, for dates of service on or after February 4, 2020. Local Medicare Administrative Contractors (MACs) are responsible for developing the payment amount for claims they receive for these newly created HCPCS codes in their respective jurisdictions until Medicare establishes national payment rates.”

RESOURCE: CMS Develops Additional Code for Coronavirus Lab Tests


New CPT code announced to report novel coronavirus test

“For quick reference, the new Category I CPT code and long descriptor are: 87635 Infectious agent detection by nucleic acid (DNA or RNA); severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) (Coronavirus disease [COVID-19]), amplified probe technique”

RESOURCE: AMA Press Release: New CPT code announced to report novel coronavirus test

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FUNDING OPPORTUNITIES

Provider Relief Funds

The CARES Act, signed by President Trump on March 27, provided $100B in relief funds to hospitals and other healthcare providers and will be used to support expenses or lost revenue attributable to COVID-19.

CARES Act $50B General Allocation (“first tranche”)

The first $30B of the of the general allocation (first distribution of the “first tranche”) was distributed to hospitals on either April 10 or April 17 (depending on the hospital’s status with United Health Group) and was proportionate to their share of Medicare reimbursement. On April 24, the remaining $20B started to be distributed. Additional funds went out to reconcile inequities of the first $30B (i.e., higher Medicaid volumes, high Medicare Advantage patients) and this totaled $9.2B (second distribution of the “first tranche”).

This left $10.8B that still needed to go out (third distribution of the “first tranche”). HOSPITALS MUST APPLY FOR A PORTION OF THIS $10.8B. This is separate and distinct from the additional $10B designated for rural hospitals and rural health clinics (see below).

>>>Please read this FAQ carefully: https://www.hhs.gov/sites/default/files/20200425-general-distribution-portal-faqs.pdf

Hospitals must also go into the portal to attest for both amounts of stimulus that you have received. This is not the TeleTracking portal. This is not the CARES Act Provider Relief Fund Payment Attestation Portal. This is the Provider Relief Fund Application Portal (built by DocuSign): https://covid19.linkhealth.com/docusign/#/step/1.

CARES Act Provider Relief Fund Distribution Summary


CARES Act $50B Targeted Allocations (“second tranche”)

Rural Providers – Another $10B has been distributed to rural hospitals and rural health clinics. Each CAH will receive a base of $1M + 4% of operating expenses from the most recent cost report; each RHC will receive a base of $100K + 4% of operating expenses from the most recent cost report.

Skilled Nursing – HHS will make relief fund distributions to SNFs based on both a fixed basis and variable basis. Each SNF will receive a fixed distribution of $50,000, plus a variable distribution ranging between $2,000 per bed for the smallest SNFs (between 5 and 25 beds) and $1,800 per bed for the largest SNFs (more than 200 beds).

“Hot Spots” – $12B is allocated for targeted distribution to hospitals in areas that have been particularly impacted by COVID-19 (“hot spots”), but will also take into account Medicare Disproportionate Share Hospital (DHS) Adjustments. Hospitals must have entered data into the TeleTracking portal by noon on April 25 to be eligible for these funds. See the Reporting section of this webpage for more information.

Treatment of Uninsured – A portion of the Provider Relief Fund will be used to reimburse healthcare providers, at Medicare rates, for COVID-related treatment of the uninsured. See coviduninsuredclaim.hrsa.gov for more information.


Paycheck Protection Program and Health Care Enhancement Act

RHC Testing – HHS, through HRSA, provided $225 million to Rural Health Clinics (RHCs) for COVID-19 testing.  These investments will support over 4,500 RHCs across the country to support COVID-19 testing efforts and expand access to testing in rural communities. Rural Health Clinics are a special designation given to health care practices in underserved rural areas by the Centers for Medicare and Medicaid Services (CMS) that help ensure access to care for rural residents. This funding is through the Paycheck Protection Program and Health Care Enhancement Act that President Trump signed into law on Friday, April 24, 2020 which specifically directed these monies to be allocated to RHCs. HRSA funded RHC organizations based on the number of certified clinic sites they operate, providing nearly $50,000 per clinic site.

Paycheck Protection Program

CARES Act Paycheck Protection Program

The Paycheck Protection Program, part of the Coronavirus Aid, Relief and Economic Security (CARES) Act is a forgivable loan designed to provide a direct incentive for small businesses to keep their workers on the payroll. Small businesses and nonprofits with fewer than 500 employees can apply through any qualified lender. Loans will have a 1% fixed interest rate, require no collateral or guarantor, and will be due in two years with no prepayment penalties or fees. Loan payments will also be deferred for six months; during that time, interest will accrue. In addition to payroll, up to 25% of the loan may be spent on mortgage interest, rent and utility payments.

Loans granted under the Paycheck Protection Program will be forgiven in full if certain requirements are met. Companies must keep workers on their payrolls for an eight-week period after the loan is granted, and loan forgiveness will be reduced depending on how the money is used. Companies must keep workers on their payroll for an eight-week period after the loan is granted. If staff counts are reduced, or salaries for employees who earn less than $100,000 annually are reduced by more than 25%, then the loan must be repaid.


Paycheck Protection Program and Health Care Enhancement Act

The Paycheck Protection Program ran out of money on 4/16/200; however, President Trump signed the Paycheck Protection Program and Health Care Enhancement Act on April 24, a $470B “phase 3.5” coronavirus stimulus package, of which $310B is additional funding for the Paycheck Protection Program. This funding is being targeted toward different recipients than the first round of funding, and $75B is set aside for grants and other mechanisms for eligible healthcare providers. As of this writing, it is believed that the additional funding is being utilized on the backlog of applications from the first round, and the SBA website states that they are currently unable to accept new applications based on available appropriations funding. Please check the SBA site frequently for updates: SBA Paycheck Protection Program.

*Note: District hospitals were originally thought to be ineligible for the Paycheck Protection Program; however, guidance from the SBA released on April 24 has clarified that hospitals otherwise eligible to receive the loan would NOT be rendered ineligible due to ownership by a state or local government if the hospital receives less than 50% of its funding from state or local government sources, exclusive of Medicaid. 

RESOURCE: PPP Loan Forgiveness Application/Instructions
*This form provides step-by-step instructions on how to calculate the forgiveness amount and includes a new exception from the loan forgiveness reduction for borrowers that made a good-faith, written offer to rehire an employee during the covered period which was rejected by the employee, among other changes and clarifications. 

RESOURCE: SBA Interim Final Rule 05/19/20

RESOURCE: NRHA Blog Post on How to Apply for a Loan Under the PPP

RESOURCE: Eide Bailly PPP vs. Emergency Injury Disaster Loan Program 

RESOURCE: SBA Paycheck Protection Program Loans FAQs

Coronavirus Small Hospital Improvement Program (C-SHIP) Grant

The HRSA Federal Office of Rural Health Policy received $180 million in the Coronavirus Aid, Relief, and Economic Security (CARES) Act to support COVID-19 related activities, of which nearly $150 million will go to hospitals responding to this health crisis. Nevada Critical Access Hospitals will receive their funds from NRHP via the Small Rural Hospital Improvement Program (SHIP) grant mechanism.

Medicare Advanced and Accelerated Payment Program

See the Finance and Operations section of this webpage for detailed information on the Medicare Advanced and Accelerated Payment Program.

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COMMUNITY COLLABORATION

Hospitals should communicate with other entities in their community regarding their role during the COVID-19 outbreak. Entities that should be involved include the County Commission, EMS, County Health Officer (if applicable), Community Health Nurse, skilled nursing, law enforcement, schools, and the Emergency Manager.


The Nevada Hospital Association’s (NHA’s) Community Resilience Program has been very active in the response to COVID-19, and NHA has provided talking points to assist Nevada hospitals in communicating with the public during this outbreak, which can be found here:

https://nvha.net/news-and-updates-on-the-covid-19/ 


NRHA, through donated services partner Legato Healthcare Marketing, is providing NRHA members free access to a communications toolkit — designed to allow customization and branding for your facility — with messaging focused on:

  • Calling first to determine if someone should be seen
  • Your rural hospital/clinic taking a leadership role to protect your community

RESOURCE: Free Rural Health COVID-19 “Call First” Communications Toolkit


Aging and Disability Services is leading a partnership with the University of Nevada, Reno School of Medicine (UNR Med) Sanford Center for Aging (SCA), UNR School of Community Health Sciences (CHS) Dementia Engagement, Education and Research (DEER) Program, Nevada Senior Services and Nevada 2-1-1, to plan and implement a comprehensive and coordinated approach to meet the needs of the potentially hundreds-of-thousands of newly-isolated elders. This new statewide, integrated aging services response to the COVID-19 crisis will carry the aspirational name of NV CAN, the Nevada COVID-19 Aging Network (CAN) Rapid Response.

RESOURCE: 3/26 Memo re: ADSD COVID-19 Crisis Update and Launch of NV COVID-19 Aging Network (NV CAN) Rapid Response


The American Hospital Association (AHA) in partnership with the Society for Health Care Strategy and Market Development (SHSMD) have identified tools and resources to help hospitals communicate effectively.

RESOURCE: AHA COVID-19 Communications Resources

RESOURCE: AHA Communications Checklist: Preparing for and Responding to COVID-19

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HUMAN RESOURCES

Families First Coronavirus Response Act

The Families First Coronavirus Response Act (FFCRA), which goes into law on April 1, 2020, will help the United States combat and defeat COVID-19 by giving all American businesses with fewer than 500 employees funds to provide employees with paid leave, either for the employee’s own health needs or to care for family members. The legislation will ensure that workers are not forced to choose between their paychecks and the public health measures needed to combat the virus while at the same time reimbursing businesses.

However, under this new law, health care providers may be exempted from paid sick leave or expanded  family and medical leave by their employer. Per the Department of Labor (DOL):

“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.”

RESOURCE: FFCRA Flow Chart v1 | FFCRA Flow Chart v2

RESOURCE: Mandatory FFCRA Poster (English | Spanish)

RESOURCE: DOL Wage & Hour Division COVID-19 and the American Workplace

RESOURCE: DOL FFCRA Fact Sheet for Employers

RESOURCE: DOL FFCRA Questions and Answers

RESOURCE: IRS COVID-19 Related Tax Credits for Required Paid Leave Provided by Small and Midsize Businesses FAQs

RESOURCE: IRS Guidance re: Paid Leave Tax Credits 03/20/20

RESOURCE: Eide Bailly FAQs for Nonprofits

RESOURCE: Homeland Security Memo on Identification of Essential Critical Infrastructure Workers During COVID-19 Response


OSHA Guidance

New guidance from the Occupational Safety and Health Administration (OSHA) relieves employers of some responsibility for investigating and recording cases of COVID-19 among employees; however, this new guidance does NOT apply to the health care sector. Health care employers must continue to investigate all COVID-19 cases among employees and record all of those acquired at work.

In addition, employers are required to record cases whenever:

  • There is objective evidence that a COVID-19 case may be work-related. This could include, for example, a number of cases developing among employees who work closely together without an alternative explanation.
  • The evidence was reasonably available to the employer. For purposes of this memorandum, examples of reasonably available evidence include information given to the employer by employees, as well as information that an employer learns regarding its employees’ health and safety in the ordinary course of managing its business and employees.

RESOURCE: OSHA Enforcement Guidance for Recording Cases of Coronavirus Disease 2019 (COVID-19) 04/10/20

RESOURCE: SCATS COVID-19 Resource Page


EEOC Guidance

On April 9, 2020 the Equal Employment Opportunity Commission issued guidance to assist employers with the proper workplace conduct that must still be followed during the pandemic.

RESOURCE: EEOC What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EECO Laws 04/09/20


Nevada Department of Public and Behavioral Health COVID-19 Message to Employers

The Nevada Department of Public and Behavioral Health (DPBH) has put forth guidelines on handling employees with symptoms–see the resource below. For more information see the Healthcare Personnel section of this webpage.

RESOURCE: DPBH Technical Bulletin 03/27/20 re: COVID-19 Message to Employers


Additional Resources

RESOURCE: Nevada Association of Employers COVID-19 Resource Webpage (NAE members only)

RESOURCE: Society for Human Resource Management COVID-19 Resource Webpage (SHRM members only)

RESOURCE: Curbside Nevada: COVID-19 Support for Clinicians and First Responders on the Front Lines


Refer to the CDC guidance for how employees can cope with job stress and build resilience during the pandemic:

https://www.cdc.gov/coronavirus/2019-ncov/community/mental-health-non-healthcare

https://www.cdc.gov/coronavirus/2019-ncov/community/mental-health-healthcare.html

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SURGE CAPACITY

Hospitals should have a plan in place to handle a potentially overwhelming influx of patients caused by the COVID-19 outbreak. Integral to addressing such a surge is the development of alternative strategies for triaging, caring for non-emergency cases, and transporting patients to tertiary facilities.

RESOURCE: AHRQ Optimizing Surge Capacity

RESOURCE: CDC COVID-19Surge Tool

RESOURCE: Northeastern University Surge Capacity Tool


Battle Born Medical Corps

On April 1, Governor Steve Sisolak announced that he signed the Battle Born Medical Corps emergency directive, aimed at expanding the healthcare workforce in Nevada to fight COVID-19. The Directive waives certain licensing requirements to allow Nevada to quickly bring additional health care workers into hospitals.

https://www.ServNV.org 

RESOURCE: BBMC – Press Release 04/04/20

RESOURCE: BBMC – How to Sign Up 04/03/20

RESOURCE: BBMC – Guidance 04/01/20


Governor’s Directive re: Expanding the Health Care Workforce

On April 1, 2020, the Governor’s Office issued a directive which included the following orders pertaining to HCP:

  • Waiver of certain licensing requirements to allow the practice of currently unlicensed skilled medical professionals during the declared emergency (a) who currently hold a valid license in good standing in another state, (b) whose license currently stands suspended for licensing fee delinquencies, (c) whose license currently stands suspended for failure to meet continuing medical education requirements; and who have retired from their practice in any state with their license in good standing;
  • Authorization of the Chief Medical Officer to approve waiver of professional licensing requirements for providers who received training in another country but are not currently licensed in the United States;
  • Medical facilities are responsible for ensuring that any provider employed or contracted with who is not licensed in Nevada during this declared emergency has notified the applicable Nevada license board or agency;
  • A provider of medical services during this emergency is authorized to supervise students in their profession to provide any emergency medical services as is appropriate to the student’s knowledge and skill level without further licensure or certification;
  • Providers of medical service are authorized to practice outside the scope of their specialization, within the limits of their competency;
  • Regulatory requirements for providers of medical services that are not compatible with the applicable Crisis Standards of Care as approved by the CMO will be suspended; and
  • Providers performing services for the COVID-19 emergency are afforded immunities and protections set forth in NRS 414.110.

RESOURCE: Nevada Crisis Standards of Care (CSC) Plan 04/02/20

RESOURCE: State of Nevada Declaration of Emergency Directive re: Expansion of Healthcare Workforce 04/01/20


Prescribing Information

RESOURCE: DEA COVID-19 Information Page

RESOURCE: Nevada State Board of Pharmacy COVID-19 Information Page

RESOURCE: Nevada State Board of Pharmacy Prescription Medications During COVID-19 Q&A


CMS Waivers to Expand Workforce Flexibility

RESOURCE: CMS COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers 03/30/20

RESOURCE: Press Release 04/09/20: Trump Administration Acts to Ensure U.S. Healthcare Facilities Can Maximize Frontline Workforces to Confront COVID-19 Crisis


Division of Public and Behavioral Health Information

If CAHs plan to expand their bed capacity, this must be done via the online licensing system: https://nvdpbh.aithent.com/Login.aspx. The fee should be waived; however, if hospitals see an issue with this they should contact DPBH.


National Practitioner Data Bank

To support healthcare entities hiring additional skilled health workforce to combat COVID-19, the National Practitioner Data Bank (NPDB) is temporarily waiving query fees. The waiver is retroactive from March 1, 2020, through May 31, 2020.

RESOURCE: HRSA NPDB Coronavirus (COVID-19) Information

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TELEMEDICINE

MEDICARE

CMS has broadened access to Medicare telehealth services so that beneficiaries can receive a wider range of services from their doctors without having to travel to a healthcare facility under a temporary and emergency basis under the 1135 waiver authority and Coronavirus Preparedness and Response Supplemental Appropriations Act.

There are three main types of virtual services physicians and other professionals can provide to Medicare beneficiaries summarized in the fact sheet shown below: Medicare telehealth visits, virtual check-ins, and e-visits.

Rural Health Clinics (RHCs) will be able to be the distant site during the emergency period.
*Note: H.R. 748 was signed into law by President Trump on Friday 3/27/2020*

For Medicare, RHCs must refer to G0071 for audio-only visits.

‘‘(8) ENHANCING TELEHEALTH SERVICES FOR FEDERALLY QUALIFIED HEALTH CENTERS AND RURAL HEALTH CLINICS DURING EMERGENCY PERIOD.— ‘‘(A) IN GENERAL.—During the emergency period described in section 1135(g)(1)(B)— ‘‘(i) the Secretary shall pay for telehealth services that are furnished via a telecommunications system by a Federally qualified health center or a rural health clinic to an eligible telehealth individual enrolled under this part notwithstanding that the Federally qualified health center or rural clinic providing the telehealth service is not at the same location as the beneficiary;‘‘(ii) the amount of payment to a Federally qualified health center or rural health clinic that serves as a distant site for such a telehealth service shall be determined under subparagraph (B); and ‘‘(iii) for purposes of this subsection— ‘‘(I) the term ‘distant site’ includes a Federally qualified health center or rural health clinic that furnishes a telehealth service to an eligible telehealth individual; and ‘‘(II) the term ‘telehealth services’ includes a rural health clinic service or Federally qualified health center service that is furnished using telehealth to the extent that payment codes corresponding to services identified by the Secretary under clause (i) or (ii) of paragraph (4)(F) are listed on the corresponding claim for such rural health clinic service or Federally qualified health center service. ‘‘(B) SPECIAL PAYMENT RULE.— ‘‘(i) IN GENERAL.—The Secretary shall develop and implement payment methods that apply under this subsection to a Federally qualified health center or rural health clinic that serves as a distant site that furnishes a telehealth service to an eligible telehealth individual during such emergency period. Such payment methods shall be based on payment rates that are similar to the national average payment rates for comparable telehealth services under the physician fee schedule under section 1848. Notwithstanding any other provision of law, the Secretary may implement such payment methods through program instruction or otherwise. ‘‘(ii) EXCLUSION FROM FQHC PPS CALCULATION AND RHC AIR CALCULATION.—Costs associated with telehealth services shall not be used to determine the amount of payment for Federally qualified health center services under the prospective payment system under section 1834(o) or for rural health clinic services under the methodology for all-inclusive rates (established by the Secretary) under section 1833(a)(3).’’

MEDICAID

Nevada Medicaid has also announced expanded access to telehealth.

Providers are encouraged to monitor the Division of Health Care Financing and Policy’s COVID-19 webpage (http://dhcfp.nv.gov/covid19/) for additional resources and information regarding telehealth coverage during this crisis. For additional questions, please send an email to dhcfp@dhcfp.nv.gov.

RESOURCE: Nevada Medicaid Telehealth Announcement 03/27/20

RESOURCE: Web Announcement: Telehealth Billing Guidelines 03/26/20

RESOURCE: Nevada Medicaid Telehealth Announcement 03/20/20

RESOURCE: Nevada Medicaid Telehealth Memo 03/17/20

The rendering provider at the distant site must bill using the most appropriate CPT code and a 02 place of service code.

RESOURCE: DHCFP Telehealth Resource Guide

Nevada Department of Health and Human Services is filing an 1135 waiver with CMS. This will allow RHCs to be the distant site.
*Note: Nevada’s 1135 waiver has not yet been filed with or approved by CMS. NRHP expects the waiver to be approved by 3/31/2020 with a retroactive effective date of 3/1/2020.*

EQUIPMENT AND APPLICATIONS

Use of non-HIPAA compliant applications:

HIPAA rules have been relaxed to allow for increased use of telehealth, meaning providers may, in good faith, use non-HIPAA platforms.

“Under this Notice, covered health care providers may use popular applications that allow for video chats, including Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype, to provide telehealth without risk that OCR might seek to impose a penalty for noncompliance with the HIPAA Rules related to the good faith provision of telehealth during the COVID-19 nationwide public health emergency.  Providers are encouraged to notify patients that these third-party applications potentially introduce privacy risks, and providers should enable all available encryption and privacy modes when using such applications. “

RESOURCE: Notification of Enforcement Discretion for Telehealth Remote Communications During the COVID-19 Nationwide Public Health Emergency

Use of telephone (audio only/no video):

VIRTUAL CHECK-INS: In all areas (not just rural), established Medicare patients in their home may have a brief communication service with practitioners via a number of communication technology modalities including synchronous discussion over a telephone or exchange of information through video or image.

Virtual check-ins can be conducted with a broader range of communication methods, unlike Medicare telehealth visits, which require audio and visual capabilities for real-time communication.

RESOURCE: Medicare Telemedicine Health Care Provider Fact Sheet

Q: Is any specialized equipment needed to furnish Medicare telehealth services under the new law?

A: Currently, CMS allows for use of telecommunications technology that have audio and video capabilities that are used for two-way, real-time interactive communication. For example, to the extent that many mobile computing devices have audio and video capabilities that may be used for two-way, real-time interactive communication they qualify as acceptable technology.

The new waiver in Section 1135(b) of the Social Security Act explicitly allows the Secretary to authorize use of telephones that have audio and video capabilities for the furnishing of Medicare telehealth services during the COVID-19 PHE. In addition, effective immediately, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 nationwide public health emergency.

RESOURCE: Medicare Telehealth Frequently Asked Questions (FAQs)

COMMERCIAL INSURERS

At this time, the Nevada Division of Insurance is not aware of any insurers requiring health care providers to use their own telemedicine portals to conduct telehealth visits. Additionally, the Nevada Division of Insurance recommends providers contact the insurers’ customer service representatives for questions/concerns with telehealth coverage.

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LONG TERM CARE

ALERT! In response to the COVID-19 pandemic, CMS has released COVID-19 Focused Survey Protocol Training for LTC. Click here to access the surveyor training materials.

CAHs with distinct-part Skilled Nursing Facilities must take extra precautions with vulnerable long-term care residents. Long-term care facilities concerned that a resident, visitor, or employee may be a COVID-2019 patient under investigation should contact their local or state health department immediately for consultation and guidance.

Ill visitors and healthcare personnel (HCP) are the most likely sources of introduction of COVID-19 into a facility. CDC recommends aggressive visitor restrictions and enforcing sick leave policies for ill HCP, even before COVID-19 is identified in a community or facility. See below for guidance on reopening nursing homes to visitors. 

Specific guidance for long-term care facilities can be found here:

https://www.cdc.gov/coronavirus/2019-ncov/hcp/long-term-care.html


Additional CDC/CMS Informational Pages

Guidance on Reopening Nursing Homes

On June 19, a questionnaire was sent to all Nevada Skilled Nursing Facilities so that the Division of Public and Behavioral Health can work with the facilities to assess their readiness to receive visitors based on the phases identified in the 5/18 CMS Memo below.

RESOURCE: DPBH Plan for Determining Phases to Allow Visitors in Nursing Facilities 06/19/20

CMS announced new guidance for state and local officials to ensure the safe reopening of nursing homes across the country. The guidance released on May 18 is part of President Trump’s Guidelines for Opening Up America Again. It details critical steps nursing homes and communities should take prior to relaxing restrictions implemented to prevent the spread of COVID-19, including rigorous infection prevention and control, adequate testing, and surveillance. The recommendations allow states to make sure nursing homes are continuing to take the appropriate and necessary steps to ensure resident safety and are opening their doors when the time is right.

RESOURCE: CMS Memo: Nursing Home Reopening Recommendations for State and Local Officials 05/18/20
*Note: Nevada facilities were notified on 5/19/20 that the state’s Chief Medical Officer is requiring COVID-19 testing for all skilled nursing facility residents and staff by Friday, May 29. 

RESOURCE: CMS Nursing Home Reopening Recommendations FAQ

Additional Resources

RESOURCE: Attorney General Ford Warns Against Stimulus Checks Being Taken From Nursing Home Residents 05/26/20

RESOURCE: CMS Memo: COVID-19 Survey Activities, CARES Act Funding, Enhanced Enforcement for Infection Control deficiencies, and Quality Improvement Activities in Nursing Homes 06/01/20

RESOURCE: CDC Infection Prevention and Control Assessment Tool for Nursing Homes Preparing for COVID-19

RESOURCE: CMS Toolkit on State Actions to Mitigate COVID-19 Prevalence in Nursing Homes May 2020

RESOURCE: CMS Letter to Nursing Home Facility Management and Staff 05/11/20

RESOURCE: CMS Memo: Interim Final Rule Updating Requirements for Notification of Confirmed and Suspected COVID-19 Cases Among Residents and Staff in Nursing Homes 05/06/20

RESOURCE: CMS Coronavirus Commission for Safety and Quality in Nursing Homes 04/30/20

RESOURCE: CMS Memo: Nursing Home Five Star Quality Rating System updates, Nursing Home Staff Counts, and Frequently Asked Questions 04/24/20

RESOURCE: CMS Memo: Long-Term Care Facility Transfer Scenarios 04/13/20

RESOURCE: Nursing Home Infection Prevention Assessment Tool for COVID-19

RESOURCE: Long-Term Care Facility Guidance 04/02/20

RESOURCE: CDC Long-Term Care Respiratory Surveillance Line List

RESOURCE: Kirkland, Washington Update and Survey Prioritization Face Sheet

RESOURCE:  CDC Nursing Homes Preparedness Checklist

RESOURCE: CMS Memo: Guidance for Infection Control and Prevention of Coronavirus Disease 2019 (COVID-19) in Nursing Homes 03/13/20 

RESOURCE: Long Term Care Resources from APIC

RESOURCE: Long-Term Care Nursing Homes Telehealth and Telemedicine Tool Kit

Key Strategies to Prepare for COVID-19 in Long-Term Care Facilities (LTCF)

>> Keep COVID-19 from entering your facility.

>> Identify infections early.

>> Prevent spread of COVID-19.

>> Assess supply of PPE and initiate measures to optimize current supply.

>> Identify and manage severe illness.

See the Reporting section of this webpage for reporting mandates specific to long-term care facilities.

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EMERGENCY MEDICAL SERVICES (EMS)

Facilities should have a plan in place with their local EMS for communication prior to the arrival of a suspected COVID-19 patient.

Facilities with their own EMS services should refer to the following websites for EMS-specific guidance:

https://www.cdc.gov/coronavirus/2019-ncov/hcp/guidance-for-ems.html


Refer to the CDC guidance for how emergency personnel can cope with stress and build resilience during the pandemic:

https://www.cdc.gov/coronavirus/2019-ncov/community/mental-health-healthcare.html


RESOURCE: DPBH Interim Pre-Hospital Guidance for Novel Coronavirus

RESOURCE: National Association of Emergency Medical Technicians (NAEMT) COVID-19 Resources

RESOURCE: CMS Ambulances: CMS Flexibilities to Fight COVID-19

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REPORTING REQUIREMENTS

Reporting to the COVID-19 White House Task Force

On March 29, 2020, Vice President Pence sent a letter to hospital administrators across the country requesting daily data reports on testing, capacity and utilization, and patient flows to facilitate the public health response to the 2019 Novel Coronavirus (COVID-19).

COVID-19 test results reporting does not apply to any NRHP hospitals as they are not doing in-house testing. However, it was also requested that capacity and utilization data be reported into the CDC National Safety Healthcare Network (NHSN) in order to assist the White House Coronavirus Task Force in tracking the movement of the virus, and to facilitate planning, monitoring, and resource allocation during the COVID-19 Public Health Emergency. Members may have also received information from TeleTracking Technologies, Inc., which has been commissioned by Health and Human Services (HHS) to create a COVID-19 Portal to capture this same information. These and other reporting options can be found under the FAQ section of the HHS letter sent out on April 10th.

RESOURCE: FEMA Coronavirus (COVID-19) Pandemic: HHS Letter to Hospital Administrators 04/10/20

However, hospitals may instead report capacity and utilization data to the State “if they have received a written release from the State and the State has received written certification from their FEMA Regional Administrator to take over Federal reporting requirements.” As of April 13th, the Nevada Hospital Association (NHA) has verified that they have been in touch with the White House COVID-19 Task Force and NHA’s daily survey is now an approved method for submitting information. This data is reported to the Governor’s Office and the results can be found here: https://nvhealthresponse.nv.gov/news-resources/daily-situation-reports/.

In addition to the $30 billion in CARES Act funds that have been distributed to hospitals, HHS has indicated that it intends to make additional targeted distributions to hospitals impacted by the coronavirus. In an effort to better determine how funds will be distributed, HHS is asking all hospitals to provide the following information through an authentication portal established by TeleTracking (an HHS vendor). HHS sent an emailed on April 12 to site administrators detailing access to the portal, however, if it is not clear who received this notification, or if there are additional questions about the registration process, questions should be directed to TeleTracking Technical Support at 877-570-6903. HHS is requesting this information be provided by 11:59 a.m. PT, Saturday, April 25.

For each facility with a Medicare Tax Identification Number (TIN):

  • Total number of Intensive Care Unit beds as of April 10, 2020
  • Total number of admissions with a positive diagnosis for COVID-19 from January 1, 2020 to April 10, 2020
  • National Provider Identifier

RESOURCE: HHS Seeking Time-Sensitive Information for CARES Act Provider Relief Payments 

On May 11, facilities were asked for information about the number of patients currently being treated for the coronavirus on an inpatient basis in order to inform current and future distributions of remdesivir to areas of greatest need. While the initial data are due by 8:00pm on May 12, facilities will be asked to provide this information on a weekly basis so the government can adjust to the changing national need for remdesivir. This information may be entered via the TeleTracking portal; however, NHA has verified that their daily survey is an approved method for submitting this information as well.

RESOURCE: AHA Special Bulletin: HHS Requests Weekly Data from Hospitals to Inform Remdesivir Distribution


Reporting to the State of Nevada

CASES–Hospitals MUST report all COVID-19 confirmed and suspect cases still awaiting laboratory confirmation to the Division of Public and Behavioral Health (DPBH) per the communicable disease reporting regulations (NRS 441A.120 and NAC 441A.085).

RESOURCE: DPBH Technical Bulletin re: Reporting of Extraordinary Occurrence of Illness 03/05/20

CHILDREN–Effective May 21, reporting of suspected Multisystem Inflammatory Syndrome in Children (MIS-C) is mandatory in Nevada.

RESOURCE: DPBH Technical Bulletin re: MIS-C and Required Reporting for MIS-C

RESOURCE: How to Report a Case of MIS-C Associated with COVID-19 in Washoe County

TEST RESULTS–Effective June 24, all in-state and out-of-state laboratories that are processing and testing samples from Nevada residents are required under severe penalties to report all COVID-19 test results to the Division of Public and Behavioral Health within 24 hours by fully completing the Nevada Confidential Morbidity Report Form.

RESOURCE: DPBH Technical Bulletin re: COVID-19 Laboratory Testing 06/24/20

DEATHS–In addition, all health care facilities MUST report immediately to their local and state health department each death that is caused by, associated with or related to COVID-19 infection consistent with CDC criteria.

RESOURCE: DPBH Technical Bulletin re: Mandatory Reporting of All COVID-19 Mortality 04/08/20

LTC–Skilled Nursing Facilities must complete a COVID-19 Daily Status Survey via a link sent by DPBH.


Nursing Home Reporting Requirements

Under the new §483.80(g), CMS is requiring facilities to report COVID-19 cases in their facility to the CDC National Health Safety Network (NHSN) on a weekly basis. CDC and CMS will use information collected through the new NHSN Long-term Care COVID-19 Module to strengthen COVID-19 surveillance locally and nationally; monitor trends in infection rates; and help local, state, and federal health authorities get help to nursing homes faster. Nursing home reporting to the CDC is a critical component of the national COVID-19 surveillance system and to efforts to reopen America. The information will also be posted online for the public to be aware of how the COVID-19 pandemic is affecting nursing homes.

NHSN data on nursing homes is publicly reporting at: https://data.cms.gov/stories/s/bkwz-xpvg

Facilities are also required to notify residents, their representatives, and families of residents in facilities of the status of COVID-19 in the facility, which includes any new cases of COVID-19 as they are identified. This action supports CMS’ commitment to transparency so that individuals know important information about their environment, or the environment of a loved one.

RESOURCE: CMS Memo: Interim Final Rule Updating Requirements for Notification of Confirmed and Suspected COVID-19 Cases Among Residents and Staff in Nursing Homes 05/06/20

RESOURCE: Long Term Care Facilities (Skilled Nursing Facilities and/or Nursing Facilities): CMS Flexibilities to Fight COVID-19

RESOURCE: CMS Memo re: Upcoming Requirements for Notification of Confirmed COVID-19 (or COVID-19 Persons under Investigation) Among Residents and Staff in Nursing Homes 04/19/20

RESOURCE: Trump Administration Announces New Nursing Homes COVID-19 Transparency Effort – Press Release 04/19/20

Skilled Nursing Facilities must also complete a COVID-19 Daily Status Survey for the State (see above) via a link sent by DPBH.


MBQIP Reporting Changes for CAHs

Medicare Beneficiary Quality Improvement Program (MBQIP) data submission will be optional over the coming months based on Critical Access Hospitals’ ability to report. This exception is based on HHS Secretary Azar’s authority to declare a public health emergency in the entire United States through the Public Health Service Act, and in alignment with the Trump Administration’s regulatory flexibilities enacted in response of these extreme and uncontrollable circumstances.

The current MBQIP policy change applies to data due for the upcoming reporting periods: Quarter 4, 2019 (Oct 1-Dec 31, 2019), Quarter 1, 2020 (Jan 1-Mar 31, 2020), Quarter 2, 2020 (Apr 1-Jun 30). Details on each MBQIP measure and impacted submission periods are available in an updated submission deadline schedule. FORHP will continue to monitor the developing COVID-19 situation and re-assess reporting requirements as needed.

Hospitals that are able to report MBQIP measures are encouraged to continue reporting, as measures will be used to inform FORHP about making improvements in care for rural populations. While hospitals direct their resources toward caring for ill patents and ensuring the health and safety of their staff, FORHP recognizes that any quality measure reporting during this national emergency may not be reflective of actual performance. Of note, the updates for MBQIP data submission align with the CMS reporting updates.

RESOURCE: MBQIP Updated Submission Deadline Schedule


OSHA Guidance

New guidance from the Occupational Safety and Health Administration (OSHA) relieves employers of some responsibility for investigating and recording cases of COVID-19 among employees; however, this new guidance does NOT apply to the health care sector. Health care employers must continue to investigate all COVID-19 cases among employees and record all of those acquired at work.

In addition, employers are required to record cases whenever:

  • There is objective evidence that a COVID-19 case may be work-related. This could include, for example, a number of cases developing among employees who work closely together without an alternative explanation.
  • The evidence was reasonably available to the employer. For purposes of this memorandum, examples of reasonably available evidence include information given to the employer by employees, as well as information that an employer learns regarding its employees’ health and safety in the ordinary course of managing its business and employees.

RESOURCE: OSHA Enforcement Guidance for Recording Cases of Coronavirus Disease 2019 (COVID-19) 04/10/20


Reporting Adverse Events

Health care providers are required to report all medication errors, serious adverse events, and clinical outcomes involving the use of hydroxychloroquine and chloroquine distributed from the Strategic National Stockpile for the treatment COVID-19 patients under the FDA Emergency Use Authorization (EUA).

In addition, health care providers are encouraged to submit report on medication errors, serious adverse events involving all other treatments for COVID-19. When reporting these events indicate that the product was being used to treat COVID-19 to ensure rapid review of the report.

Both health professionals and patients can submit Adverse Event reports online to FDA MedWatch www.fda.gov/medwatch/report.htm, by postage-paid Form FDA 3500 (available at http://www.fda.gov/downloads/AboutFDA/ReportsManualsForms/Forms/UCM163919.pdf), by fax (1-800-FDA-0178), or by calling 1-800-FDA-1088 to request a reporting form.

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EMTALA

One March 9, 2020, CMS issued a memorandum which addresses implications of COVID-19 in compliance with EMTALA. More information can be found in the attached memo.

CMS 1135 Waiver re: EMTALA

CMS is waiving the enforcement of section 1867(a) of the Social Security Act (the Emergency Medical Treatment and Active Labor Act, or EMTALA). This will allow hospitals, psychiatric hospitals, and CAHs to screen patients at a location offsite from the hospital’s campus to prevent the spread of COVID-19, in accordance with the state emergency preparedness or pandemic plan.  (Source: CMS COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers, page 25)

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HIPAA/PRIVACY

Protected health information:

It is especially important during extraordinary circumstances such as the current COVID-19 pandemic that healthcare providers understand the rules that apply to the privacy and confidentiality of patients’ health information. LiCON’s Risk Manager, Linda Garrett, has put together a memorandum addressing HIPAA regulations which apply to protected health information.

RESOURCE: Memo re: Coronavirus Risk Management Concerns/HIPAA

RESOURCE: Confidentiality Rules:  Uses and Disclosures of PHI Related to Coronavirus (COVID-19) Exposures and Infections For Nevada Heath Care Entities and Providers


There is a limited waiver of HIPAA sanctions and penalties during the current public health emergency which applies to hospitals only (not clinics). The hospital must have enacted their emergency plan in order for the waiver to apply, and there is a 72-hour time limit. The waiver affects the following provisions:

  • Patient authorization to speak with family members or friends involved in their care;
  • Honoring a request to opt out of the facility directory;
  • Distribution of the Notice of Privacy Practices;
  • Patient’s right to request privacy restrictions; and
  • Patient’s right to request confidential communications

*Note: Failure to follow STATE LAWS could still result in a breach!

RESOURCE: HHS COVID-19 & HIPAA Bulletin – Limited Waiver of HIPAA Sanctions and Penalties During a Nationwide Public Health Emergency


The HIPAA Privacy Rule permits a Covered Entity to disclose the protected health information (PHI) of an individual who has been infected with, or exposed to, COVID-19, with law enforcement, paramedics, other first responders, and public health authorities without the individual’s HIPAA authorization, in certain circumstances, as outlined in the resource below.

RESOURCE: OCR COVID-19 and HIPAA: Disclosures to law enforcement, paramedics, other first responders and public health authorities

Use of non-HIPAA compliant applications:

HIPAA rules have been relaxed to allow for increased use of telehealth, meaning providers may, in good faith, use non-HIPAA platforms.

“Under this Notice, covered health care providers may use popular applications that allow for video chats, including Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype, to provide telehealth without risk that OCR might seek to impose a penalty for noncompliance with the HIPAA Rules related to the good faith provision of telehealth during the COVID-19 nationwide public health emergency.  Providers are encouraged to notify patients that these third-party applications potentially introduce privacy risks, and providers should enable all available encryption and privacy modes when using such applications. “

RESOURCE: Notification of Enforcement Discretion for Telehealth Remote Communications During the COVID-19 Nationwide Public Health Emergency

RESOURCE: OCR FAQs on Telehealth and HIPAA during the COVID-19 nationwide public health emergency

Security and Remote Work:

If any employees are working from home, it will be very important to ensure the security of the home setup in order to protect the hospital’s system and patients’ PHI. NRHP’s CIO has provided some guiding principles for working remotely, which can be found below.

RESOURCE: NRHP Guiding Principles for Working Remotely

RESOURCE: Free Webinar from ArchProCoding: Facilitating HIPAA Compliance During the COVID 19 Pandemic

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REGULATORY ENVIRONMENT

State of Nevada

All Directives and Declarations from Governor Sisolak and State of Nevada Executive Department can be found here:

PHASE 3.5: Paycheck Protection Program and Health Care Enhancement Act – 4/24/20 (H.R.266)

Paycheck Protection Program and Health Care Enhancement Act (H.R. 266) is a $484 billion law that increases funding to the Paycheck Protection Program and also provide more funding for hospitals and testing for COVID-19.

This Act is referred to as “Phase 3.5” as it includes “interim” funding that replenishes one of the programs established by the CARES Act (Phase 3). The CARES Act created the $349-billion Paycheck Protection Program, which provided low-interest loans to small businesses that were forgivable if they maintained their employees and payroll. The $349 billion was fully allocated within 13 days. During those 13 days, 1.6 million loans were approved by nearly 5,000 banks and other lenders.

Provisions of the Paycheck Protection Program and Health Care Enhancement Act include the following.

  • Appropriates an additional $320 billion of funding for the Paycheck Protection Program, which provides low-interest loans for payroll costs and other expenses to small businesses that are forgivable under certain circumstances. Of that amount, $60 billion is for PPP loans made by small banks, small credit unions, and community financial institutions
  • Appropriates an additional $10 billion for emergency Economic Injury Disaster Loans
  • Expands eligibility for emergency Economic Injury Disaster Loans to farms and agricultural-related businesses.
  • Appropriates $50 billion for Small Business Administration disaster loans.
  • Appropriates an additional $75 billion to the Public Health and Social Services Emergency Fund for health care providers’ expenses or lost revenues related to coronavirus.
  • Appropriates $25 billion to the Public Health and Social Services Emergency Fund for researching, developing, validating, manufacturing, purchasing, administering, and expanding capacity for COVID-19 testing.
  • Appropriates $2.1 billion for salaries for the Small Business Administration.

PHASE 3: The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) – 3/27/20 (H.R.748)

The Coronavirus Aid, Relief, and Economic Security Act (the CARES Act) was signed into law on March 27, 2020 and provides resources and flexibility for rural hospitals, such as:

New Access to Capital

  • New funding for health care providers, including $150M that will go directly to CAHs via the Small Hospital Improvement Program (SHIP)
  • Small business loans via the “Paycheck Protection Program”

Medicare/Medicaid Payment Improvements and Flexibilities

  • Temporary elimination of Medicare sequestration
  • Expanded option for accelerated payments
  • Medicaid DSH cut reduction and delay

Telehealth Access and Flexibilities

  • Additional funding for telehealth
  • Improved Medicare beneficiary access to telehealth
  • RHCs as distant sites

RESOURCE: AHA CARES Act: Provisions to Help Rural Hospitals

RESOURCE: H.R. 748 The Coronavirus Aid, Relief, and Economic Security Act 

RESOURCE: The Small Business Owner’s Guide to the CARES Act

PHASE 2: The Families First Coronavirus Response Act (FFCRA) – 3/18/20 (H.R.6201)

The Families First Coronavirus Response Act (FFCRA) was signed into law on March 18, 2020 and per a statement, the White House, “provides paid leave, establishes free coronavirus testing, supports strong unemployment benefits, expands food assistance for vulnerable children and families, protects front-line health workers, and provides additional funding to states for the ongoing economic consequences of the pandemic, among other provisions.” Among other things, this new law includes:

  • The Emergency Family and Medical Leave Expansion Act (EFMLA), which amends the Family and Medical Leave Act of 1993 (FMLA) to provide up to 10 weeks of protected paid leave to eligible employees for a coronavirus related reason
  • The Emergency Paid Sick Leave Act (EPSLA) provides full time employees up to a two-week period of paid sick leave for coronavirus related reasons

*Note: Health care providers may be exempted from Paid Sick Leave or Expanded Family and Medical Leave by their employer under the FFCRA. Per the Department of Labor, a health care provider is defined 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. 

RESOURCE: Department of Labor: COVID-19 and the American Workplace

RESOURCE: H.R.6201 – Families First Coronavirus Response Act

PHASE 1: Coronavirus Preparedness and Response Supplemental Appropriations Act – 3/6/20 (H.R.6074)

The Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020 (H.R. 6074) is an act of Congress enacted on March 6, 2020. The legislation provided emergency supplemental appropriations of $8.3 billion in fiscal year 2020 to combat the spread of coronavirus disease 2019 (COVID-19) and counter the COVID-19 pandemic.

Broken down by category, the bill provides funding for the following purposes:

  • More than $3 billion for “research and development of vaccines, as well as therapeutics and diagnostics”
  • $2.2 billion “in public health funding to aid in prevention, preparedness and response efforts — including $950 million to support state and local agencies”
  • Almost $1 billion for “medical supplies, health-care preparedness, Community Health Centers and medical surge capacity”
  • $1.25 billion to fight COVID-19 internationally.[9]

Emergency Declaration 1135 Waivers

On March 13, 2020, the President declared the ongoing Coronavirus Disease 2019 (COVID-19) pandemic of sufficient severity and magnitude to warrant an emergency declaration for all states, tribes, territories, and the District of Columbia pursuant to section 501 (b) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. 5121-5207 (the “Stafford Act”).

The Trump Administration has issued an array of temporary regulatory waivers and new rules, which apply for the duration of the emergency declaration, to equip the healthcare system with the flexibility it needs to respond to the COVID-19 pandemic.

The goals of these temporary waivers are as follows:

  1. To ensure that local hospitals and health systems have the capacity to handle a potential surge of COVID-19 patients through temporary expansion sites (aka CMS Hospital Without Walls);
  2. To remove barriers for physicians, nurses, and other clinicians to be readily hired from the community or from other states so the healthcare system can rapidly expand its workforce;
  3. To increase access to telehealth in Medicare to ensure patients have access to physicians and other clinicians while keeping patients safe at home;
  4. To expand in-place testing to allow for more testing at home or in community based settings; and
  5. To put Patients Over Paperwork to give temporary relief from many paperwork, reporting and audit requirements so providers, health care facilities, and States can focus on providing needed care to beneficiaries affected by COVID-19.

RESOURCE: Summary of COVID-19 Emergency Declaration Waivers & Flexibilities for Health Care Providers

RESOURCE: Hospitals: CMS Flexibilities to Fight COVID-19

RESOURCE: Long Term Care Facilities (Skilled Nursing Facilities and/or Nursing Facilities): CMS Flexibilities to Fight COVID-19 

RESOURCE: Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs): CMS Flexibilities to Fight COVID-19 

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