Hospitals Must Post Crisis Care Guidelines on Website
Effective Jan. 6, all California hospitals are required to publicly post their crisis care continuum guidelines, another facility’s guidelines, or the state’s guidelines on their website, per All Facilities Letter (AFL) 20-91. Additionally, hospitals must notify their local California Department of Public Health (CDPH) district office and their local public health department via email that they have adopted and publicly posted this policy – including a link to the website posting. Hospitals are expected to have plans that best fit their facility and regional needs and processes, while following ethical principles, health equity goals, and civil rights laws. CHA urges all hospitals to post their guidelines in an easy-to-find location on their website.
HHS Adds Optional Data Reporting Fields for Health Care Personnel and Patient Vaccinations
The federal Department of Health & Human Services (HHS) recently announced updates to COVID-19 hospital reporting. HHS added seven new optional fields related to health care personnel and patient vaccinations that hospitals can report on each Wednesday. While currently optional, the fields are likely to become mandatory in the future. An interim final rule added collecting and reporting COVID-19 data to the Medicare and Medicaid conditions of participation.
As detailed by this new guidance, the new fields that are available for optional reporting through the CHA COVID-19 Tracking Tool beginning Jan. 20 are:
- Previous Week’s COVID Vaccine Doses
- Unvaccinated Personnel
- Personnel Receiving a Partial Series
- Personnel Receiving a Complete Series
- Total Personnel
- Previous Week’s First COVID Vaccine Doses
- Previous Week’s Final COVID Vaccine Doses
CHA will provide hospitals and systems currently using the data upload feature with a revised template in advance. The revised data dictionary includes these new optional fields highlighted in blue. In addition, to assist with data reporting, CHA worked with CDPH to update the data reporting guidance document. Questions can be directed to COVIDTracker@calhospital.org.
HHS Updates Provider Relief Fund Reporting Requirements
On Jan. 15, HHS updated its Provider Relief Fund (PRF) reporting requirements to reflect changes required by the recently passed Consolidated Appropriations Act of 2021 (CAA). In addition to calculating lost revenue attributable to coronavirus based on the difference between 2019 and 2020 actual patient care revenue, PRF recipients may now choose from two other methodologies using:
- Budgeted Revenue: The difference between 2020 budgeted and 2020 actual patient care revenue. If a provider elects this method they must use a budget that was established prior to March 27, 2020.
- Alternative Reasonable Method: Any reasonable method of estimating lost revenue. If a recipient uses an alternative reasonable method for calculating lost revenues attributable to coronavirus, the recipient must submit a description and an explanation of why the methodology is reasonable, and establish how the identified lost revenues were attributable to coronavirus. The updated guidance also states that the use of an alternative reasonable method will increase the likelihood of an audit.
Also, as required by the CAA, the guidance clarifies that a parent organization may transfer targeted distribution funds received by a subsidiary. However, the original targeted distribution recipient remains responsible for reporting on the use of funds.
HHS has opened the PRF reporting portal for recipients to register. However, it has delayed reporting to give recipients ample time to familiarize themselves with the updated reporting requirements in advance of required submission deadlines. HHS did not announce new reporting deadlines as part of this update.
DMHC Proposes Emergency Regulations on Patient Transfers
On Jan. 12, the Department of Managed Health Care proposed to adopt emergency regulations on the transfers of enrollees per state or local public health orders. Once approved by the Office of Administrative Law and filed with the Secretary of State, the regulations will be effective and remain in effect for 180 days. The draft regulations state the following:
- An order issued by the state public health officer or a local health officer that directs or allows hospitals or other health care facilities to transfer patients to other facilities is covered by these regulations.
- Plans shall not require prior authorization or prior notice for a transfer and shall cover the medically necessary costs of moving an enrollee between facilities.
- Plans must reimburse the receiving facility for all medically necessary services provided during the first 72 hours the enrollee is treated at the receiving facility.
- After 72 hours, the plan shall continue to reimburse the receiving facility for all medically necessary services if:
- The facility notifies the health plan that it is treating their enrollee within 72 hours of receiving the enrollee.
- The plan does not disapprove the facility’s request to continue providing medically necessary care to the enrollee.
- If the plan disapproves the request to continue providing care after 72 hours, it shall reimburse the facility for services up to the time the plan effectuates the enrollee’s transfer or is discharged from the receiving facility.
State Revises Vaccine Allocation Guidelines
California has revised its vaccine allocation guidelines to allow vaccination of all persons 65 and over, if vaccine is available. In addition, CDPH now recommends the use of 50% of doses providers have received as second doses.
Biden Announces Pandemic Relief Legislative Package
In a speech to the nation on Jan. 14, President-elect Biden announced his first legislative initiative (see fact sheet and summary). His first priority is a $1.9 trillion proposal that provides economic stimulus, support for state and local governments, expanded federal support for vaccine distribution, and other measures. It is not clear if there is specific relief directed at hospitals, but CHA will continue to work with the California congressional delegation to ensure that hospitals’ needs are addressed.
CDPH Announces Residential Care Sites as Discharge Option for Some COVID-19 Patients
CDPH has issued AFL 21-02, which announces that the California Department of Social Services has developed residential alternate care sites as a potential discharge option for COVID-19-positive patients needing a residential level of care and intermittent incidental medical support. The goal of these residential alternate care sites is to care for COVID-19 patients who reside in residential care facilities for the elderly or adult residential facilities that can no longer care for them, as well as to support the decompression of hospitals.
As noted in the AFL, the residential alternate care sites are low-acuity sites that provide some nursing and medical services. Individuals admitted must be at a residential care level and may require some “health related assistance” but not 24-hour skilled nursing. The admission criteria for each site may vary based on the staffing level, equipment available, and physical space.
Valencia Branch Lab Testing Extended for Hospitals
The state has announced that the use of the Valencia Branch Lab (VBL) for testing capacity of hospital health care personnel has been extended indefinitely. There are two partnership pathways for hospitals choosing to use the VBL: using the lab to test hospital personnel only or using it to test hospital personnel and community members. The indefinite extension applies to both options.
For more information on partnering with the Valencia Branch Lab, see the updated Expanded COVID-19 Testing Capacity in Partnership with the State (new link) summary or visit the state’s testing website.
Cal OES Issues Letter on Decedent Management
The Governor’s Office of Emergency Services (Cal OES) has notified hospitals, medical examiners, county sheriff coroners, and others about the resources and support available through the Coroners’ Mutual Aid and Mass Fatality Management System. While recognizing that California has not experienced a mass fatality situation as a result of COVID-19, the letter instructs stakeholders — should the situation arise — to follow specific provisions on the Cal OES website.
The letter also reminds hospitals to immediately assign an individual to continually assess capacity management and outreach if they have not yet done so.
CDPH Issues Guidance for SNFs on Using Salesforce to Request Fit Testing for Staff
CDPH has issued AFL 21-05, which explains the process skilled-nursing facilities should use for requesting resources through Salesforce to support fit-testing of respiratory protection for staff. Under the new process, which took effect Jan. 13, the state has contracted with Concentra to provide training and fit testing for nursing facility staff who must wear respiratory protection to safely perform their essential duties. Facilities will now be able to enter fit-testing requests into Salesforce for their MHOAC to consider and coordinate. Additional information about the Salesforce platform is available in AFL 20-79.
On-Demand Webinar Offers Tools to Help Care for the Caregiver
As the COVID-19 surge extends into the winter and continues to stretch front-line health care workers both mentally and physically, CHA reminds hospitals that the Hospital Quality Institute’s Care for the Caregiver webinar is available as an on-demand recording. The webinar includes practical and necessary tools to assist hospitals and their employees in creating a peer support model for adverse events such as the COVID-19 pandemic. Additionally, the webinar offers information on how to engage in empathic conversation with both patients and families.
Summary of Jan. 12 CDPH Call
CDPH has provided a summary of its recent weekly call with health care facilities.