Nursing Home Infection Control Distribution – $2 Billion Incentive Payment Plan Announced

The Department of Health and Human Services’ (HHS) Health Resources and Services Administration (HRSA) previously announced the distribution of $5 billion in PRF payments to eligible skilled nursing facilities to protect residents from the impact of COVID-19.

On August 27,2020, HHS distributed the initial $2.5 billion of this funding to support facilities’ COVID-19 infection control efforts, including by conducting appropriate testing, acquiring necessary personal protective equipment (PPE), investing in staff, and establishing COVID-19 isolation facilities. Eligible facilities automatically received a per-facility payment of $10,000 plus a per-bed payment of $1,450 in this initial distribution.

On September 3, 2020, HHS announced  that the next $2 billion incentive payment allocation would be based on measuring nursing home performance through required nursing home data submissions and distributing payments based on these data. Data submissions will come from the Certification and Survey Provider Enhanced Reports (CASPER), Nursing Home Compare (NHC), and Provider of Services (POS) systems. The payments will be divided into four performance periods (September, October, November, December), lasting a month each with $500 million available to nursing homes in each period. Nursing homes will be assessed based on a full month’s worth of the aforementioned data submissions, which will then undergo additional HHS scrutiny and auditing before payments are issued the following month, after the prior month’s performance period.

Using data from the Centers for Disease Control and Prevention (CDC), HHS will measure nursing homes against a baseline level of infection in the community where a given facility is located. CDC’s Community Profile Reports (CPRs) include county-level information on total confirmed and/or suspected COVID-19 infections per capita, as well as information on COVID-19 test positivity. Against this baseline, facilities will have their performance measured on two outcomes:

  1. Ability to keep new COVID infection rates low among residents.
  2. Ability to keep COVID mortality low among residents.

To measure facility COVID-19 infection and mortality rates, the incentive program will utilize data from the National Healthcare Safety Network (NHSN) LTCF COVID-19 module. CMS issued guidance in early May requiring that certified nursing facilities submit data to the NHSN COVID-19 Module.  Data from this module will be used to assess nursing home performance and determine incentive payments.

As with other PRF payments, within 90 days of receiving this payment, you must sign an attestation confirming receipt of the funds and agreeing to the Terms and Conditions of payment. Should you choose to reject the funds, you must also complete the attestation to indicate this.

The HHS guidance on the provider relief funds has been ever changing and often conflicting. The FAQs continue to be updated frequently. HW&Co. is here to assist you in any way we can. Please visit the HW&Co. Current Events Center on our website for additional resources or contact your HW Healthcare Advisor if you need assistance.

Disclaimer:  This information is subject to change and is based upon our current understanding as of the issue date. This is a constantly evolving process as HHS has been issuing new or changed guidance on a frequent basis