Mandatory Vaccination Requirement for Nursing Home Staff Announced
The Biden administration has announced that all nursing homes must require their staff be vaccinated against Covid-19 in order to continue receiving Medicare and Medicaid funding.
President Joe Biden announced on Wednesday 8/18 that he is directing the Department of Health and Human Services to draw up new regulations making employee vaccination a condition for nursing homes to participate in Medicare and Medicaid, the officials said. The move represents a significant escalation in Biden's campaign to get Americans vaccinated and the tools he is willing to use, marking the first time he has threatened to withhold federal funds in order to get people vaccinated.
The move comes as the more transmissible Delta variant now accounts for 99% of Covid-19 cases in the United States and as data shows a link between low vaccination rates in certain nursing homes and rising coronavirus cases among residents.
The White House also posted a Fact Sheet and that can be accessed here: https://www.whitehouse.gov/briefing-room/statements-releases/2021/08/18/fact-sheet-president-biden-toannounce- new-actions-to-protect-americans-from-covid-19-and-help-state-and-local-leaders-fight-the-virus/
Universal Vaccine Policy for Genesis Employees
Genesis continues their strong commitment to patient health and safety and has announced a universalvaccine policy for employees. This policy requires all staff working within Genesis HealthCare facilities and service lines to receive a first vaccine dose by August 23. Genesis Rehab therapists working in private nursing homes or other settings not owned/operated by Genesis are expected to adhere to facility policy regarding vaccination. We continue to encourage and support vaccination of all staff as the best way to protect both patients and staff from the virus.
Regulatory Updates and Resources
CDC Recommends Third Vaccine Dose
The CDC is recommending that moderately to severely immunocompromised people receive an additional dose of mRNA COVID-19 vaccine at least 28 days after a second dose of Pfizer or Moderna COVID-19 vaccine. This includes residents who have:
- Been receiving active cancer treatment for tumors or cancers of the blood
- Received an organ transplant and are taking medicine to suppress the immune system
- Received a stem cell transplant within the last 2 years or are taking medicine to suppress the immune system
- Moderate or severe primary immunodeficiency (such as DiGeorge syndrome, Wiskott-Aldrich syndrome)
- Advanced or untreated HIV infection
- Active treatment with high-dose corticosteroids or other drugs that may suppress your immune response
As of 8/18/21, the CDC is expected to announce a recommendation for a third vaccine dose for elderly and nursing home patients, most likely beginning in September. The SNF industry is awaiting further information as to how these doses will be delivered in the SNF settings.
Targeted Probe and Educate (TPE) program to Resume
The Centers for Medicare and Medicaid Services (CMS) announced via a MLN Connects article that the agency is restarting the Targeted Probe and Educate (TPE) program.
The TPE program is a process that a Medicare Administrative Contractor (MAC) can utilize when providers are selected by Medical Review. The TPE review process may include up to three rounds of a prepayment or post-payment probe review with education. If there are continued high denials after the first three rounds of reviews, the MAC will refer the provider and results to CMS and CMS will determine additional action, which may include additional rounds of review, 100 percent prepayment review,extrapolation, referral to the Recovery Auditor (RA), or referral for revocation.
The goal of the TPE program is to reduce provider burden by helping Medicare providers quickly improve accuracy and reduce claim denials and appeals through increased one-on-one education. Should you receive an audit from your MAC, CMS encourages you to take advantage of the TPE education, and get up to 3 rounds of educational claim review to help you bill accurately.
CMS Posts CY 2022 MPFS Proposed Rule
On July 13, 2021, the Centers for Medicare and Medicaid posted the public inspection version of a proposed rule titled, Medicare Program; CY 2022 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Provider Enrollment Regulation Updates; Provider and Supplier Prepayment and Post-payment Medical Review Requirements. The proposed rule puts forth provisions expected to be effective on 01/01/2022. The proposed rule was published to the Federal Register on 07/23/2021. Public comments are due by 09/13/2021. CMS has also provided summaries of the proposed rule in a fact sheet and a press release.
This rule includes the 15% reduction in payment for services provided by Physical or Occupational Therapy Assistants, as well as reductions in payment for some therapy CPT codes. Genesis Rehab is actively involved with industry groups in advocating for mitigation of these payment reductions.
Upcoming Solutions Webinar
Join us for the next Solutions webinar on September 16, 2021 at 1:00 PM Eastern for “Skin and Wound Management.” The event is free but registration is required. Click here to register.
