Critical access hospitals (CAHs) that accept Medicare and Medicaid payments must follow the Centers for Medicare & Medicaid Services (CMS) Conditions of Participation (CoPs). The CMS Critical Access Hospital Manual has seen multiple changes to regulations and interpretive guidelines. Since a hospital’s payment is based on compliance with the conditions, it is imperative hospitals make the necessary changes to remain in compliance.
As Michigan begins the third year of living with COVID-19, new cases, hospitalizations and deaths are trending downward and hopes are high that a new variant will not emerge to cause another surge of disease. The state reported there were 2,770 cases recorded for March 17 and 18 (including about 825 cases attributable to older lab results), 648 adults and children were hospitalized with confirmed and suspected cases, and 50 deaths caused by the disease were recorded over the two-day period. These numbers are fractions of what was seen in December and January, when Michigan hospitals were at or near inpatient capacity.
The MHA continues to keep members apprised of pandemic-related developments affecting hospitals through email updates and the MHA Coronavirus webpage. Important updates are outlined below.
MIOSHA Will Not Increase COVID-19 Inspections of Healthcare Facilities
Barton Pickelman, director of the Michigan Occupational Safety and Health Administration (MIOSHA) within the Department of Labor and Economic Opportunity, has confirmed that MIOSHA will not be conducting additional, focused, COVID-19 compliance inspections of healthcare facilities in Michigan. Although a March 2 memo issued by the federal Occupational Safety and Health Administration (OSHA) announced a 90-day COVID-19-focused inspection initiative for hospitals and skilled nursing care facilities, Pickelman noted that MIOSHA and other state plans are not required to adopt the federal OSHA initiative. Because MIOSHA has already conducted state emphasis programs for healthcare over the past two years, it is not adopting the federal inspection initiative.
Separate from the OSHA inspections, surveyors from the Michigan Department of Licensing and Regulatory Affairs (LARA) will continue to check for compliance with requirements of the Centers for Medicare & Medicaid Services and state licensing agencies during regular survey visits or in response to specific complaints. LARA will confirm that facilities have written policies and protocols in place surrounding COVID-19 screening processes, are following their policies as written, and that these policies and protocols can allow either active or passive screening procedures, consistent with guidance from the Centers for Disease Control and Prevention (CDC).
MHA Creates State/Federal COVID-19 Guidelines Tracker for Providers
To help hospitals and health systems keep track of COVID-19 guidelines, the MHA has developed a document outlining state and federal COVID-19 protocols for healthcare personnel, including vaccination, masking and COVID-19 testing guidelines from both the CDC and the Michigan Department of Health & Human Services (MDHHS). The downloadable tool can be found on the MHA’s website on the COVID-19 webpage under Resources for Healthcare Professionals. Those with questions may contact Lucy Ciaramitaro at the MHA.