IHA Daily Briefing: March 24

Tuesday, March 24, 2020
CMS Approves Illinois’ 1135 Waiver Request
Correction: March Hospital Assessment Payments Due 3/31
Illinois COVID-19 Update
National COVID-19 Update
Possible FEMA Funding for COVID-19 Expenses
FMAP Increases 6.2% for COVID-19 Crisis
SOPH Reimbursement Update
DHS Issues Guidance on State-Funded Grants
New COVID-19 Medicare Severity DRG Grouper
COVID-19 Employer Resources from IHA Strategic Partner

CMS Approves Illinois’ 1135 Waiver Request
The Centers for Medicare & Medicaid Services (CMS) today approved an additional 11 state Medicaid waiver requests under Section 1135 of the Social Security Act, including Illinois’ request submitted by the Illinois Dept. of Healthcare and Family Services.  The waivers provide relief on a number of fronts, such as prior authorization and provider enrollment requirements, suspending certain nursing home pre-admission reviews, and facilitating reimbursement to providers for care delivered in alternative settings due to facility evacuations.  

Correction: March Hospital Assessment Payments Due 3/31
The Illinois Department of Healthcare and Family Services (HFS) has notified IHA that it is extending the due date for the March Hospital Assessment for one week from March 24 to March 31.  All hospitals are encouraged to make sure they make the payment by the March 31 due date to facilitate the April Hospital Assessment payments. See HFS’ notice.

Illinois COVID-19 Update
At today’s press briefing, the Illinois Dept. of Public Health (IDPH) announced 250 new COVID-19 cases, for a total of 1,535 cases in 32 counties statewide. Four new deaths were reported for a total of 16 deaths. IDPH Director Ngozi Ezike, M.D., said thus far, 16% of COVID-19 cases in Illinois required hospitalization, with 4% requiring ICU admission. Approximately 92% of the deaths in Illinois are by those 60 years of age and older.

Governor J.B. Pritzker noted efforts to increase testing COVID-19 capacity in the state. In addition to the state labs, there are four commercial labs and 15 hospital labs processing COVID-19 test specimens. Currently about 1,500 tests are being processed daily in Illinois. He is looking to increase daily testing capacity by 2,800 by providing labs with equipment they need to process more tests.

Besides testing, the Governor said he is also focusing on COVID-19 treatment, saying the healthcare system needs to be able to take care of those who are ill. In a matter of 24 hours, 180 people have applied to rejoin the healthcare workforce after he loosened regulations to allow inactive or retired doctors, nurses and other select healthcare workers to temporarily practice.

Gov. Pritzker noted that his administration has been working with hospital leaders and the Illinois Emergency Management Agency (IEMA) to increase healthcare capacity statewide. Thus far, 66 of the state’s 200 hospitals have set up triage tents with IEMA or on their own, and 26 hospitals are in the process of setting up triage tents. In addition, hospitals are retrofitting their buildings and off-site locations to increase bed capacity.

In his quest for more personal protective equipment (PPE) and supplies, the Governor said he has spoken to President Trump and he has committed to sending 300 ventilators and 300,000 N95 masks for the state.

Details on the Governor's measures to increase testing and hospital capacity are outlined in a press release.

Today, IHA released its COVID-19 Legal Resource, a compilation of federal, state and local issues and legal resources for members. It will be updated and distributed to members periodically. 

In its latest health alert, the Chicago Dept. of Public Health provides guidance to city hospitals about disposition of COVID-19 persons under investigation and confirmed cases who are unstably housed or returning to homeless shelters and other high-risk settings. The alert also provides resources available to discharge planners.

See IHA’s COVID-19 webpage for a variety of resources in a central location.

National COVID-19 Update
Current CDC figures show a total of 44,183 confirmed and presumptive positive cases of COVID-19 in the U.S. in 54 states and U.S. territories, with 544 deaths. New York State leads the nation with more than 21,600 cases.

The National Institutes of Health (NIH) has launched a website with educational resources for coronavirus workers dealing with the spread of COVID-19. The NIH says its initial focus is to build a virtual safety training delivery platform in partnership with private sector e-learning companies with the capability to deliver synchronized just-in-time web-based training across the country in targeted high-risk industrial sectors. Additionally, a cadre of COVID-19 safety trainers and virtual safety advisors is being created to leverage the delivery of advanced training technology to frontline responders.

On March 22 the U.S. Food and Drug Administration (FDA) published guidance providing flexibility around and expanding the availability of ventilators and other respiratory devices to treat patients during the COVID-19 public health emergency. While the FDA expects providers to use FDA-cleared ventilators when possible, it will not object to limited modifications without premarket notification for and approval of those devices. Examples of flexibilities include: changes to the ventilator motor to allow an alternate supplier to meet the required design specifications, and changes to the material in the ventilator tubing to allow for more flexible material sourcing. More information can be found here.

The latest WHO situation report shows more than 332,000 COVID-19 cases globally, with over 14,500 deaths. The European Region now leads the world in cases and deaths, with more than 171,000 confirmed cases with over 8,700 deaths. The Western Pacific Region ranks second with more than 95,600 confirmed cases and more than 3,400 deaths.

Possible FEMA Funding for COVID-19 Expenses
As part of President Trump’s emergency declaration in response to the COVID-19 pandemic outbreak, the Federal Emergency Management Agency (FEMA) was directed to assist eligible entities, including hospitals, with the health and safety actions they take on behalf of the American public. FEMA has indicated that it will be waving the 30-day deadline that is usually required and will accept applications through the duration of the Public Health Emergency.

As part of that assistance, eligible emergency protective measures taken at the direction or guidance of public health officials could be reimbursed under Category B of the FEMA Public Assistance program. Pertinent to hospitals, FEMA may reimburse for the provision of eligible medical care which includes items such as:

  • Triage and medically necessary tests and diagnosis;

  • Treatment, stabilization, and monitoring;

  • First-aid assessment and provision of first aid;

  • A one-time 30-day supply of prescriptions for acute conditions or to replace maintenance prescriptions;

  • Vaccinations for survivors and emergency workers to prevent outbreaks of infectious and communicable diseases;

  • Durable medical equipment;

  • Consumable medical supplies;

  • Temporary facilities, such as tents or portable buildings for treatment of survivors;

  • Leased or purchased equipment for use in temporary medical care facilities;

  • Security for temporary medical care facilities; and

  • Use of ambulances for distributing immunizations and setting up mobile medical units.

IHA advises members to consider tracking and documenting all services, resources and supplies used as part of their response to the COVID-19 outbreak. This documentation will be needed should it be determined eligible expenses exist.

More details can be found in an IHA memo.

FMAP Increases 6.2% for COVID-19 Crisis
Today, the Trump Administration took steps to implement provisions of the Families First Coronavirus Response Act (Public Law 116-127) that provide states with enhanced federal Medicaid funding during the 2019 Novel Coronavirus (COVID-19) national emergency, including the release of implementation guidance.  Section 6008 of the Families First Coronavirus Response Act provides for a possible 6.2% increase in the Federal Medical Assistance Percentage (FMAP) for each state and territory. This increase will be retroactive to Jan. 1, 2020 and will continue through the end of the quarter in which the public health emergency for COVID-19 ends. For grant awards covering Jan. 1, through March 31, 2020, states will receive the funds in their Payment Management System (PMS) account no later March 25.

All state Medicaid agencies are eligible for the increased FMAP as long as they adhere to the conditions outlined in the Families First Coronavirus Response Act.  The guidance document released today provides answers questions on various aspects of the FMAP increase.

SOPH Reimbursement Update
The Illinois Department of Human Services (DHS) has requested that IHA share its Communication Alert with hospitals regarding State-Operated Psychiatric Hospital (SOPH) COVID-19 protocols and reimbursement.

IHA negotiated this agreement for hospitals providing inpatient psychiatric care to uninsured patients in qualifying regions.  DHS has a tentative goal of restarting patient admissions at all three SOPHs currently diverting patients to community hospitals by March 30.  As background, see DHS’ original Communication Alert and IHA’s follow-up member memo clarifying DHS protocols.

DHS Issues Guidance on State-Funded Grants
On Mar. 23, the Illinois Dept. of Human Services (DHS) issued a Communication Alert with contracted providers on sustaining funding for organizations that are unable to provide services or only able to provide limited services due to the public health emergency. DHS is following federal guidance that permits grantees to continue to charge salaries and benefits for active grants, with the following specifications:

  • Expense-Based Grants: Payments for expense-based grants will be made as normal.

  • Fixed-Rate Grants: Continue to submit billing information. DHS will make grant payments equal to “average monthly billings x reimbursement rate.” The portion of the grant payment not supported by service billings will need to be expended for costs (e.g. salaries and benefits, facility and administrative costs).

  • DHS Funded Medicaid Fee-For Service: Continue to submit billing information. DHS will make retention payments equal to “average monthly billings x reimbursement rate.” Retention payments are to be expended for costs (e.g. salaries and benefits, facility and administrative costs).

New COVID-19 Medicare Severity DRG Grouper
The Centers for Medicare & Medicaid Services (CMS) issued a corrected announcement regarding the Medicare Severity-Diagnosis Related Group (MS-DRG) Grouper to recognize the new ICD-10-CM diagnosis code, U07.1, for COVID-19. The ICD-10 MS-DRG Grouper software package to accommodate this new code, Version 37.1 R1, is effective for discharges on or after April 1, 2020. If diagnosis code U07.1, COVID-19, is reported as a principal diagnosis, it will only exclude itself from acting as a Major Complications/Comorbidities (MCC) under the CC Exclusions List. Assignment of U07.1, COVID-19 can be found here.

COVID-19 Employer Resources from IHA Strategic Partner
Responding to COVID-19 has presented employers with several challenges during an evolving and unprecedented public health crisis. IHA Strategic Partner Gallagher Insurance Point, a leader in employee benefits and human resources consulting, offers IHA members insight and resources focused on organizational needs.

In early March, Gallagher released a survey to assess employer response and preparedness to COVID-19. The survey addresses telecommuting, full wage continuation, compensation policy and communication strategy. Early results are available here, with updates provided as more employers respond.

Among over 700 employers so far, the survey found:

  • 77% modified their policies to allow employees who do not normally telecommute to work remotely;

  • 72% developed a COVID-19 communication strategy;

  • 61% are prepared to offer additional pay for healthy workers to take on additional shifts, job responsibilities and/or fill in for workers unable to come to work; and

  • 54% will provide full compensation to employees whose jobs are not conducive to telecommuting or those unable to work due to public health quarantine, office closure and travel restriction.

Gallagher has several resources to guide employers in their response to COVID-19, including pandemic preparedness, employee communication strategies and information on how insurance policies might be affected. You can also read a Gallagher article about the bipartisan Families First Coronavirus Response Act.

With an exclusive focus on organizational well-being, Gallagher can help protect your business and your top resource—your employees. See an IHA video to learn more about Gallagher Insurance Point.