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COVID-19 Tools & Resources: HHS/Centers for Medicare and Medicaid Services

LeadingAge Michigan is the convener for policy and advocacy discussions around critical senior issues for not-for-profit and mission based providers. We partner with a broad base of like-minded entities focused on policies that support member ability to serve Michigan seniors. This page is designed to provide a current set of resources that will assist in maintaining a safe and calm environment during the potential pandemic that is now developing.





MIHAN/ MSP Communications

During this pandemic emergency, MDHHS has been sending out many of its updates through MIHAN – the Michigan Health Alert Network. This is a web-based communication system established by MDHHS and other entities to alert key public health, healthcare and public safety personnel to situational awareness and important, but non-emergency health related information.

We have recently noted that some members may not be familiar with or registered with MIHAN; and some have found the registration process difficulty and lengthy. We are working with MDHHS to determine how best to assist members in registering and will provide updates as we receive information.

Many communications have also been issued via the Michigan State Police – as part of the pandemic response. The first messages about the Visitation Guidance were received through that mechanisms. Members who wish to receive their alerts can sign up here.


Nursing Home Testing Guidance – UPDATED TODAY!!

MDHHS has posted an updated Nursing Home COVID-19 Testing Financial Guidance to Nursing Home COVID-19 Plan. Please note in particular the following change in submission email below and important reminder about submission of confidential or sensitive data:

  • Effective July 6th, all Nursing homes should begin submitting their testing reimbursement forms to the Bureau of Audit at:
  • Please submit the testing reimbursement forms only. Please do NOT send any confidential information or beneficiary specific data to the above email.

Documents attached include:

Please note that the email for submitting testing reimbursement forms has changed to the above.


HHS Renews Public Health Emergency

The US Department of Health and Human Services has announced that it will extend the public emergency by another 90 days. This allows continuation of a set of policies that support health care providers through the crisis. Some of these flexibilities include:

• A 20% add on payment for inpatient COVID care
• Increased federal proportion of Medicaid funding
• Insurance coverage for COVID testing without co-pays or deductibles
• Blanket Section 1135 and state waivers


CMS Nursing Home Training/QIO

On Thursday, July 2, CMS and the QIO program is presenting a training on Transparency: Resident and Family Notification. This training is part of the Nursing Home Training Series. Members can register here, and get information on training updates and previous recordings.


Blanket Waiver for Extended Benefit Periods

On 6/26, CMS issued its guidance for billing COVID related care during the public health emergency. Within that guidance (see narrative starting on page 9), they clarified use of the extended benefit period waiver as appropriate for emergency related issues only.

Using the authority under Section 1812(f) of the Act, CMS is waiving the requirement for a 3-day prior hospitalization for coverage of a SNF stay, which provides temporary emergency coverage of SNF services without a qualifying hospital stay, for those people who experience dislocations, or are otherwise affected by COVID-19. In addition, for certain beneficiaries who exhausted their SNF benefits, it authorizes renewed SNF coverage without first having to start a new benefit period (this waiver will apply only for those beneficiaries who have been delayed or prevented by the emergency itself from commencing or completing the process of ending their current benefit period and renewing their SNF benefits that would have occurred under normal circumstances).

Note that the waiver for qualifying hospital stays applies to all Medicare beneficiaries.


CMS Issues FAQs on Nursing Home Visitation

Yesterday, CMS issued a FAQ document based on guidance issued in QSO 20-30-NH. They provide clarifications about compassionate care situations that might be outside the definition of end of life care as well as use of outside visits during phases for reopening. There are some activities that may be able to be started before Phase 3 – but the state will be issuing final guidance and orders. It can be viewed at


Medicare Coverage of COVID Testing 

CMS issued notice to Medicare Advantage Plans to cover coronavirus testing for nursing home residents and patients. The instruction aligns with the CDC recent update of nursing home testing guidelines for COVID. Medicare Advantage plans must continue not to charge any cost-sharing. The memo to Medicare Advantage Plans, dated June 19, specifically includes instructions to cover testing for asymptomatic individuals as part of public health surveillance. These changes are effective July 6, 2020


Nursing Home Testing Requirements 

Yesterday, MDHHS issued its requirements for ongoing testing for nursing homes. This guidance is very similar to that issued on 6/10 for all healthcare providers – although testing is now required for nursing homes only. The epidemic order, detailed guidance, and plan template are included below.



SNF Testing Guidance Issued

MDHHS issued its directives for SNF COVID testing this afternoon. Generally, the guidance mirrors what we have discussed with some distinctions. An additional protocol has been included as highlighted below:

• Initial testing of all residents and staff
• Testing of all new or returning residents during intake and routine quarantine of new residents (unless testing done within past 72 hours)
• Testing any resident or staff with symptoms or exposure
• Weekly testing of all residents and staff with any positive cases among residents or staff until 14 days after the last new positive
Testing of all staff in Regions 1 though 5, and testing al all staff in Region 7, at least once between the date of this order and July 3, 2020
• Weekly testing of staff in regions of medium risk or higher on the MI Safe Start Map

Note that these provisions apply to hospice facilities as well. Facilities must complete a plan by June 22 for how to conduct testing in compliance with the guidance. Residents have the right to refuse if they choose. Resource information is included.

Additionally, we are hearing that new data elements will be added to EMResource for SNF reporting. And a new website is being launched regarding the nursing home strategy. As of 6/14/2020:

Resident confirmed cases: 7163
Residents Recovered or Recovering: 4919
Resident COVID 19 Deaths: 1947
Staff confirmed cases: 3133
Staff COVID 19 deaths: 20


MDHHS Issues Testing Recommendations


After a long wait, MDHHS has issued its recommendations for ongoing testing for health care providers. There were early indications that these directions would be mandatory, however current guidance appears to be a recommendation only. LeadingAge Michigan will review these guidelines during tomorrow’s Safe and Calm Webinar at 11:00 a.m. Members can register here if they are not already signed up for the webinar series.


CMS Increases Infection Control Penalties for Nursing Homes

Today, CMS announced increased civil money penalties for nursing homes who demonstrate a pattern of issues surrounding infection control. States will also have to submit a corrective action plan if they have not completed focused infection control surveys on all nursing homes by July 31. Based on preliminary data from the CDC nursing home reporting system (NHSN), 25% of facilities had at least one COVID infection, and 20% had at least one death.

Early analysis shows that One Star facilities were more likely to have large numbers of COVID – 19 cases than those with a five star rating. CMS will start posting COVID data on the Nursing Home Compare site on Thursday, June 4.


Kaiser Family Foundation Reviews Payment for Testing

The Family First Coronavirus Response Act (FFRCA) passed on March 18, 2020 provided that all forms of public and private insurance, including self-funded plans must cover testing and costs associated with testing with no cost sharing. This included high deductible plans as well. Medicare will also cover antibody testing. Additionally, FFRCA provided an option to states to cover testing for the uninsured through Medicaid under 100% federal Medicaid funding. Michigan is not currently listed as a state participating.

CMS has announced that Medicare will reimburse providers up to $100 per test, depending on the test. Some newer tests are more expensive. The CARES Act also provides that private plans must all fully cover out of network test costs. But it does not prohibit out-of-network providers from billing patients directly for the test. This could deter some persons from getting tested.

There has been no comprehensive federal legislation that limits cost sharing for COVID treatment, however providers who receive grants through the CARES Act are prohibited from balance billing for all care provided to patients with presumptive or confirmed cases.


CMS Issues SNF Reopening Recommendations

CMS issued QSO 20-30-NH for state and local officials to consider in mitigating risks for vulnerable residents in nursing homes. States may utilize a phased-in approach and should consider: community transmission; facility transmission; adequate staffing; and access to adequate testing. These recommendations are communicated with all survey and certification staff.


CMS Issues Resources for States and Nursing Homes 

Today, CMS released a toolkit that is a rather lengthy list of state responses to COVID needs - organized by categories such as infection control practices, testing, and staffing. Additionally, CMS has announced that Quality Improvement Organizations (QIOs) are reaching out to provide virtual technical assistance based on individual nursing home history of infection control citations.


CMS Required Reporting to CDC/NHSN for SNFs

The NHSN LTCF team will be hosting an additional Enrollment webinar on Friday May 15, 2020 from 3:00-4:00 ET. This webinar will be an abbreviated version of the earlier enrollment webinar, with a focus on commonly asked questions and tips for completing the final stage of NHSN enrollment for the LTCF COVID-19 reporting module. The webinar will be in a listen-only platform, however participants will have an opportunity to submit questions, and subject matter experts (SMEs) will respond during the session. Members can register at


HHS Updates Blanket Waivers for Nursing Homes 

CMS has updated several provisions pertinent to nursing homes within its 1135 Blanket Waivers. 


CMS Updated Nursing Home Flexilbilities

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


CMS 20-29-NH

Today, CMS issued 20-29 NH to provide guidance related to the interim final rule for SNF reporting that was available on May 1. Please note that the final rule is not expected to be released until 5/8 and is effective on that date. The first set of data must be reported no later than Sunday, May 17, 2020. The minimum period for reporting is every seven days, although they request that data be submitted on the same day of the weak consistently. The guidance is attached and updates several areas of guidance for nursing homes, including changes to the focused survey, reporting requirements for residents and their families, posting facility level COVID situation data. The infection control requirements for nursing homes have been updated to include when and to whom possible incidents of communicable disease or infections should be reported.


CMS Issues Proposed Rule for Nursing Home Reporting

Late Friday, CMS listed an interim final rule for Nursing Home COVID Reporting to the CDC effective May 1 with the first week reporting anticipated for May 8. Members will have to submit through a dedicated portal using National Health Safety Network. Please note that although this is a proposed rule, it is in effect as of May 1. Facilities who have not started the enrollment process for reporting should do so immediately.


Paycheck Protection Program

The US Small Business Administration has updated its website to include a list of participating lenders for the Paycheck Protection Program.








QSO 20-28-NH - Issued 4/24/2020








CMS is extending its limitations on survey activities until further notice. Because health care inspections have been suspended temporarily, CMS will post them on the Nursing Home Compare Website but not include them in the Star Ratings for inspections on or after 3/4/2020. Quality Measure and PBJ reporting will be included in the scheduled 4/29/2020 update, but this may change for later updates as PBJ reporting deadlines have been temporarily postponed.








CMS Issues Toolkit to Help States with Workforce Challenges




Using ASPR TRACIE (ASPR Technical Resources, Assistance Center, and Information Exchange), CMS has issued a COVID-19 Healthcare Workforce Toolkit to assist state decision-makers and coalitions dealing with staffing issues.  The tool kit can be reviewed here.  















CMS Issues QSO 20-26-NH - Nursing Home Transparency Rules












CMS has issued announced new regulatory requirements that require nursing homes to report COVID-19 cases to the CDC as well as to local and state health departments. (Note that EO 2020-50 also requires reporting to MDHHS.) The process for this reporting, including the required format and frequency, will be issued in later rulemaking. Additionally, CMS will require that nursing facilities notify residents/representatives of every single confirmed infection within 12 hours of occurrence when the new rules are published. Facilities must also report whenever three or more residents or staff exhibit new onset of respiratory symptoms within 72 hours. Facilities must inform residents and families their plan and actions taken to mitigate risk. Failure to comply with these rules may result in enforcement actions.










CMS Issues Recommendations for Communities with Low/Stable COVID Incidence






The Centers for Medicare and Medicaid Services has issued new recommendations for facilities with low and stable COVID incidence, moving toward a gradual transition to increase in-person care. These guidelines work to encourage health care providers to coordinate with local public health officials, review the availability of PPE, workforce issues, testing availability, and facility readiness to safely serve the population should a surge recur. New recommendations can be found here.







CMS QSO-20-25-NH Long Term Care Facility Transfer Scenarios




This memo clarifies guidance for residents who will need to be transferred within the facility, to another long term care facility, or to other non-certified locations approved by the state. As covered under CMS 1135 Blanket Waivers for COVID-19









COVID-19 Stimulus Bills - Family First COVID Response Act and Coronavirus Aid, Relief, and Economic Security Act: Medicare and SBA Opportunities. New FAQs Available for Member Review











$34 Billion Sent to Providers in Medicare Advanced Payments







CMS reported it will be distributing $30 billion of $100 billion in CARES grants for emergency provider relief this week. Second round of funding will come shortly and prioritize children’s hospitals, pediatricians, and nursing homes. Funds are allocated on the amount of Medicare Revenue – which might penalize hospitals with high uninsured care. Hospital groups in general have been opposed to use of the money to cover COVID care for the uninsured.










More CMS Guidance on Infection Control







Today, CMS issued new guidance designed to help ensure local hospitals can rapidly expand their capacity to isolate and treat patients infected with COIVD-19. The guidance includes: (1) New instructions for dialysis facilities and (2) Revised guidance for hospitals that expands recommendations on screening and visitation restrictions, discharge to subsequent care locations, staff screening, testing, and return to work practices.








CMS Issues Recommendations for Non-Emergent and Elective Services




This document provides recommendations to limit those medical services that could be deferred using a tiered framework that will help prioritize care and services. Decisions are to remain the responsibility of local healthcare delivery systems and includes state and local health officials. Each clinical situation must be assessed to ensure conservation of resources







PBJ Data Submission Temporarily Suspended



CMS has already suspended PBJ submissions and the next quarter data submission due date was May 15. Even if the waiver is removed before then, CMS has confirmed that the May 15 data submission will not be required.








CMS April 2, 2020 Updated Guidance for Long Term Care 





Nursing homes must immediately ensure that they are currently complying with infection control guidance especially hand hygiene, utilize the infection control self- assessment, and follow CDC guidance for nursing homes and conservation of PPE. Additionally, symptom screening must be conducted for all you are entering the facility.




CMS COVID-19 Blanket Waivers










CMS Expands the Accelerated and Advanced Payment Program







In order to increase cash flow to providers of services and suppliers impacted by the 2019 Novel Coronavirus (COVID-19) pandemic, the Centers for Medicare & Medicaid Services (CMS) has expanded our current Accelerated and Advanced Payment Program to a broader group of Medicare Part A providers and Part B suppliers. The expansion of this program is only for the duration of the public health emergency. Interested members can review a CMS fact sheet.









Trump Administration Provides Financial Relief For Medicare Providers






On Saturday, CMS released notice that they have approved a streamlined accelerate advanced payment process for all Medicare providers. Attached is the fact sheet referenced as well as several MACs request forms (Request for Accelerated Payment Form, Form Approved Form, NGS Request Form). We will be confirming the process to obtain advance payments with various MACs shortly.



CMS Beneficiary Notice Delivery Guidance


CMS Beneficiary Notice Delivery Guidance provides flexibilities for delivering notices.




Enhanced Medicaid Funding



CMS has released FAQs regarding the increase in the amount of federal assistance to states for Medicaid.





Resources for State Agencies for Medicaid Home and Community Based Services

LeadingAge has issued an article on CMS COVID-19 Resources for state agencies related to home and community based services.







CMS Announces Focused Surveys for Acute and Continuing Care Providers




All non-nursing home providers are also encouraged to review this guidance that includes survey requirements for certified Medicare/Medicaid providers and also applies a template for other residential settings. Members can access QSO-20-20-ALL and the LeadingAge Michigan Summary for Acute and Continuing Care Providers.






CMS Announces Focused Survey Process for Nursing Homes

CMS has created a focused but also enhanced survey process, including a member self-assessment tool for use during the viral outbreak. Members can access QSO-20-20-ALL and the LeadingAge Michigan Summary for Nursing Homes and a streamlined version of the Infection Control Tool here




CMS PACE Guidance






Medicare Payment Amounts for COVID-19 Testing






CMS 1135 Waivers and Nursing Home Visitation Guidance under CMS





QSO 20-18-HHA


CMS updated guidance includes information for home health workers about assessing risk before entering homes or shortly thereafter.




QSO 20-14-NH Revised


LeadingAge Michigan Summary




QSO-20-15 Hospital/EMTALA



Emergency Medical Treatment and Labor Act (EMTALA) Requirements and Implications Related to Coronavirus Disease 2019 (COVID-19)




QSO-20-16 Hospice


Guidance for Infection Control and Prevention Concerning Coronavirus Disease 2019 (COVID-19) by Hospice Agencies





QSO – 20-14-NH Revised



Guidance for Infection Control and Prevention of Coronavirus Disease 2019 (COVID-19) in nursing homes (REVISED)





QSO – 20-14-NH



Guidance for Infection Control and Prevention of Coronavirus Disease 2019 (COVID-19) in nursing homes




QSO – 20-13 Hospitals


Guidance for Infection Control and Prevention Concerning Coronavirus Disease (COVID-19): FAQs and Considerations for Patient Triage, Placement and Hospital Discharge






Suspension of Survey Activities






QSO 20-10 CLIA




Notification to Surveyors of the Authorization for Emergency Use of the CDC 2019-Novel Coronavirus (2019-nCoV) Real-Time RT-PCR Diagnostic Panel Assay and Guidance for Authorized Laboratories





QSO 20-09-ALL



Information for Healthcare Facilities Concerning 2019 Novel Coronavirus Illness (2019-nCoV)




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