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 Coronavirus-Mandated SNF Staffing, PPE Reporting Starts

The Centers for Disease Control and Prevention National Healthcare Safety Network (NHSN) COVID-19-mandated reporting for nursing centers has started, according to the latest update from the American Health Care Association/National Center for Assisted Living (AHCA/NCAL).

The association recommends that providers accurately report the staffing and personal protective equipment (PPE) situation at their facilities based on normal standards and guidance for PPE and staffing, not conservation guidance. 

“Federal and state governments will use these data to hold nursing homes accountable for care and services provided and to identify who needs additional resources,” AHCA/NCAL said. “It is important that the data reported to NHSN give an accurate picture of staffing and PPE, as well as the other areas collected in NHSN.”

Given the instructions on NHSN, providers reporting that they have what they need tells the Centers for Medicare & Medicaid Services (CMS) that providers possess enough PPE and employ enough staff to follow conventional and normal practices, which will likely be used by surveyors when comparing what they find during their surveys.

AHCA/NCAL recommends using these guidelines.

Staffing: NHSN asks, “Does your organization have a shortage of staff and/or personnel?” Answer YES if any of the following are occurring during the time period of reporting.

--Staffing less than the facility needs or internal policies for staffing ratios prior to COVID or based on increased needs since COVID

--Employing contingency or crisis strategies for staffing shortage

--Using more agency staff than used before the pandemic

--Using volunteers for staffing needs more than what the facility may have used prior to the pandemic

--Using any temporary positions per waiver allowances (such as temporary nurse assistant or temporary feeding assistant)

PPE: NHSN asks, “Do you have enough for one week?” each for N95 masks, surgical masks, eye protection, gowns, gloves, and alcohol-based hand sanitizer. Answer NO if any of the following are occurring during the time period of reporting.

--Employing any conservation strategies for PPE use; if you are not able to use PPE per conventional transmission-based precautions in place before the pandemic you should answer NO

--Using alternative PPE such as cloth masks or other types of face coverings, clothing, or other types of coverings instead of surgical gowns, or glasses for eye protection

--Reusing any single-use supply item such as gown or masks

--If additional residents in the next week will need to be placed on precautions, it will compromise your PPE supply

--If additional staff in the next week will need to use PPE when returning to work, it will compromise your PPE supply

--If visitors or contractors in the next week need to visit, it will compromise your PPE supply 

As a reminder, skilled nursing facilities (SNFs) should keep documentation of their efforts to secure more PPE as well as staffing. “You should report to your local and state health departments that you are employing contingency and crisis strategies to conserve PPE and staffing,” AHCA/NCAL said.

In other developments, CMS said it will fix a glitch in the new Patient-Driven Payment Model (PDPM). AHCA/NCAL said SNF PPS Part A claims were not being paid day-1 variable per diem rates when a beneficiary switched from Medicare Advantage (MA) to fee-for-service Medicare Part A during a stay.

AHCA/NCAL said it reported to CMS that this was inconsistent with current policy.

CMS agreed and on May 8 published a 
change request to the Medicare Administrative Contractors (MACs) to update the claims processing systems retroactive to Oct. 1, 2019. A summary of the changes is posted in this MLN Matters article. Although this is retroactive, the systems changes will not occur until Oct. 5, 2020.

Providers should notify billing staff that the MACs will adjust any improperly adjusted SNF PPS claims related to a beneficiary switch from MA to fee-for-service during a stay only if brought to their attention, so that the prior days count is corrected to exclude the MA days, the association said.

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