The Health Resources Services Administration (HRSA) recently opened an application process for $25.5 billion in federal COVID-19 funding for providers. The same application process is used for both Provider Relief Fund (PRF) Phase 4 and American Rescue Plan (ARP) Rural payments.
The PRF Phase 4 funding is open to a broad range of providers with changes in operating revenues and expenses due to the pandemic. ARP Rural funding is open to providers who serve rural beneficiaries of Medicare, Medicaid or the Children’s Health Insurance Program, known in Michigan as MIChild.
Additional information, including eligible provider types and application instructions, is available on the HRSA website. The agency must receive applications by Oct. 26, and members are encouraged to begin the process as soon as possible. Registration for webinars featuring guidance on using the application portal are also listed online. HRSA intends to start distributing the ARP funds by late November and the PRF funds by mid-December.
A leadership change in the Michigan Department of Health and Human Services ( MDHHS) took place Jan. 22 when Robert Gordon announced his resignation and Elizabeth Hertel was appointed to replace him as director of the department. The MHA has a longstanding relationship with Hertel, who has served at both the MDHHS and Trinity Health, and issued a statement of support in response to the announcement. Hertel begins her tenure as director as COVID-19 continues to evolve and affect every Michigander’s life. The MHA keeps members apprised of pandemic-related developments affecting hospitals through email updates and the MHA Coronavirus webpage. Important updates are outlined below.
President Biden Releases Vaccine Operational Plans
The Biden administration announced Jan. 26 new details of its plans to increase vaccine supply and distribution to states in the coming weeks and months. The state of Michigan has issued updated operational plans that will coordinate with these federal efforts and resources. These plans will continue to be modified going forward. Highlights of the Biden vaccine plan are:
Supply Forecasting: The Biden administration plans to provide states with a three-week planning forecast of vaccine supply, which will allow states to communicate advanced information about allocations to providers and improve their planning capabilities.
More Vaccine Overall: The federal government is working to purchase 200 million additional doses of Pfizer and Moderna vaccine (100 million of each). The president also increased the national vaccination goal to 1.5 million people per day rather than 1 million.
More Vaccine to States: The president stated that starting next week, states would receive approximately 17% more vaccine each week than they have previously.
Syringe Supply: Biden is using federal actions to increase production of critical vaccine-related supplies, especially the syringes needed to extract the sixth dose from Pfizer vials.
As the state of Michigan continues to hone its plan to coordinate with federal efforts, the MHA is providing feedback to the MDHHS on ensuring the allocation formulas are fair and equitable for hospitals and health systems of all sizes and geographies. The association advised the state to incorporate data on both inpatient and outpatient measures into its allocation calculations. Additional information will be shared as it becomes available. Members with questions may contact Ruthanne Sudderth at the MHA.
State Announces Protect Michigan Commission to Promote, Improve Vaccine Acceptance
Gov. Gretchen Whitmer Jan. 25 appointed the bipartisan Protect Michigan Commission, which represents a diverse array of industries, professions, and backgrounds. Housed within the MDHHS, the commission will help raise awareness of the safety and effectiveness of an approved COVID-19 vaccine, educate state residents and help protect their health and safety. The governor has named Spectrum Health President and CEO and MHA Executive Committee Member Tina Freese Decker as a co-chair of the commission, and MHA Senior Vice President of Public Affairs & Communications Ruthanne Sudderth as a commission member.
The Protect Michigan Commission, first announced in December, serves in an advisory capacity to Whitmer and the MDHHS. It is tasked with providing public leadership to elevate and reinforce the importance of an approved COVID-19 vaccine, identifying barriers that may impede Michigan residents’ acceptance of an approved COVID-19 vaccine — including identifying areas or groups that are likely to experience vaccine hesitancy — and develop an outreach action plan designed to overcome these barriers. The commission must complete its work and submit a brief final report to the governor by Dec. 31, and appointees will serve until the group’s dissolution. The MHA will keep members apprised of the commission’s work.
New Reporting Guidelines Issued for Provider Relief Fund Disbursements
The U.S. Department of Health and Human Services (HHS) recently announced that it is modifying the reporting timeline and reporting requirements for the Provider Relief Fund (PRF). The modifications delay the reporting deadlines in response to the year-end passage of the Coronavirus Response and Relief Supplemental Appropriations Act.
The HHS indicated that providers that received at least $10,000 in PRF funds may now register for the PRF Reporting Portal. This will allow them to eventually submit information to comply with HHS reporting requirements, though data reporting is not yet required. The registration process is expected to take 20 minutes and must be completed in a single session.
The HHS released new reporting guidance that supersedes previously issued guidance. The new guidance maintains the two general reporting categories — unreimbursed COVID-19 expenses and lost patient revenue — but is more flexible in what is allowed. Under the new guidance, providers may use “the difference between 2020 budgeted and 2020 actual patient care revenue.” Health systems are now also able to transfer funds received from targeted PRF distributions to other hospitals within the system.
The MHA will notify members of any substantive developments in PRF reporting requirements. Members with questions should contact Jason Jorkasky at the MHA.
AHA Partner Offers PPE Donation for Hospitals
Through a partnership between the American Hospital Association (AHA) and the web application HealthEquip, hospitals in need of personal protective equipment (PPE) may receive donations of surgical masks, face shields and other PPE for a small processing fee and shipping costs. Participating hospitals will be matched based on their need and limited available quantities of donated equipment.
Hospitals may sign up to HealthEquip’s DonorExchange to enter PPE requests; the HealthEquip team will match hospitals with the donated PPE and arrange shipment. HealthEquip also offers the ability to purchase specific PPE though its Marketplace. Members with questions about supply chain issues may contact Adam Carlson or Rob Wood at the MHA.
As the Thanksgiving holiday approaches, the number of hospitalizations due to COVID-19 continues to rise. The MHA keeps members apprised of pandemic-related developments affecting hospitals through email updates and the MHA Coronavirus webpage. Important updates are outlined below.
Vaccine Studies Show 95% Effectiveness
Moderna announced Nov. 16 that the latest trials and studies of its COVID-19 vaccine show 95% effectiveness, and Pfizer updated its findings Nov. 18, announcing its vaccine also shows 95% effectiveness. Moderna’s results stem from its Phase 3 clinical trial of 30,000 individuals, and Pfizer’s efficacy rate resulted from a final analysis of its trial with more than 41,000 volunteers. Both vaccines use messenger RNA (mRNA) technology to cause the effective immune response. A key difference between the vaccines is that Moderna’s vaccine can be safely stored in freezers at about 25 degrees Fahrenheit (minus 4 degrees Celsius), a temperature easily reached by a normal freezer. The Pfizer vaccine requires ultracold storage only achieved by specialized freezers or dry ice.
Pfizer applied with the Food and Drug Administration for emergency use authorization of its vaccine Nov. 20, and Moderna expects to soon apply for the authorization. Although distribution dates are not yet certain, the Michigan Department of Health and Human Services (MDHHS) has advised that providers should be prepared to accept vaccine by early December to ensure expedient distribution and administration when shipments begin. Members with questions may contact Ruthanne Sudderth at the MHA.
Provider Relief Fund Further Clarified
The U.S. Department of Health and Human Services (HHS) has issued two important clarifications related to Provider Relief Fund (PRF) reporting.
The HHS had previously stated that providers could claim only the value of depreciation for COVID-19-related capital purchases with useful lives of more than 12 months. However, after urging from the American Hospital Association and the MHA, the agency stated that expenses for capital equipment, facilities projects and inventory may be fully expensed in cases where the purchase was directly related to the prevention, preparation for and response to COVID-19. Examples of such purchases include:
Upgrading heating, ventilation and air conditioning systems to support negative pressure units.
Retrofitting COVID-19 units.
Enhancing or reconfiguring intensive care unit capabilities.
Leasing or purchasing temporary structures to screen and/or treat patients.
Leasing permanent facilities to increase hospital capacity.
The HHS also clarified that providers’ reporting of net patient revenue should NOT include payments received from or made to third parties that relate to care not provided in 2019 or 2020.
COVID-19 ICU Best Practices Follow-Up Webinar Offered Nov. 24
A Nov. 11 COVID-19 webinar titled “ICU Management & Treatment of COVID-19 Patients” was hosted under the MI-COVID19 registry continuous quality improvement initiative and provided meaningful discussion for participants. As a result, a follow-up webinar has been scheduled for noon to 1 p.m. EST Nov. 24. Objectives include:
Summarizing the latest COVID-19 intensive care unit (ICU) guidelines and recommendations.
Discussing best practices for management of critically ill COVID-19 patients.
Identifying resources and creating a network for ICU leaders in Michigan to advance the care of critically ill COVID-19 patients.
CDC Offers Education on Telehealth and Health Equity Dec. 8
The Centers for Disease Control and Prevention (CDC), through its Clinician Outreach and Communication Activity division, will host an educational event via Zoom from 2 to 3 p.m. EST Dec. 8 that will focus on telehealth and health equity. Details and access information for the event are available online. Presenters from Kaiser Permanente and the Veterans Health Administration will discuss how telehealth has affected health equity in their patient populations before and during the COVID-19 pandemic.
Topics will also include challenges and opportunities related to telehealth implementation. Presenters will share strategies to expand access that can reduce disparities and improve culturally responsive care to help achieve health equity within each organization. In addition, presenters from the CDC will share telehealth strategies that incorporate the CDC’s frameworks for Addressing Health Equity in Public Health Practice.
In associated news, the MHA recently released its Pledge to Address Racism and Health Inequities that was approved by the MHA Board of Trustees at its Nov. 4 meeting (see related article).
COVID-19 Relief Facility Application Now Open
The state has released the application for being designated a COVID-19 Relief (CR) Facility, which are designed to allow eligible Nursing Facilities to retain COVID-19-positive residents. These facilities will meet criteria established in Senate Bill 1094 to care for COVID-19-positive residents who become ill and do not require hospital-level care. The purpose of the CR Facilities is to provide care in place with enhanced infection control measures for individuals with confirmed COVID-19 who have not met the criteria for discontinuation of Transmission-Based Precautions and have limited access to the state’s Care and Recovery Centers. All approved CR Facilities may retain, or readmit after acute care, their own COVID-19-positive residents.
Facilities must meet certain criteria to qualify for CR Facility designation or admission of new COVID-19-positive residents, as detailed in Bulletin Number MSA 20-73 from the Medical Services Administration. The bulletin also provides a list of documents and details applicants should have prepared before applying.
Completed applications should be submitted by 5 p.m. Dec. 1. The MDHHS, in partnership with the Michigan Department of Licensing and Regulatory Affairs, will review applications as they are received. Notification of application status will be contingent upon the volume of applications received. However, it is estimated that facilities seeking CR Facility designation may expect to be notified about the determination within one to two weeks of application submission. Questions about CR Facilities may be submitted to the MDHHS via email.
The number of COVID-19 cases is climbing, and Michigan hospitals are again experiencing an influx of patients battling the disease. 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.
Hospitals, Businesses Call for Collective Action to Avert More COVID-19 Deaths
The MHA released a joint statement to statewide media Oct. 22 that was signed by physician leaders of hospitals and healthcare systems throughout Michigan. The letter includes 28 signatures that represent 110 of Michigan’s 137 hospitals plus MHA Chief Medical Officer Gary Roth, DO. The goal of the statement is to make clear that, regardless of state law, executive orders or local public health directives, hospitals and healthcare systems across the state are standing as a united front in policies and interventions that will help fight the spread of COVID-19. It also emphasizes that the recent jump in COVID-19 cases across Michigan puts the state’s entire healthcare system at risk of another capacity crisis and asks the public to take the necessary steps to prevent the spread of this deadly disease.
Several media outlets across the state have reported on the letter and healthcare providers’ united stance to stave off COVID-19. Members that were not included on the statement and would like the signature of their facility’s physician leader added to the MHA website copy should contact Lucy Ciaramitaro at the MHA.
In addition, members of the Michigan Economic Recovery Council (MERC) sent a letter Oct.. 21 to Gov. Gretchen Whitmer, Senate Majority Leader Mike Shirkey and House Speaker Lee Chatfield, urging collective action to prevent additional deaths from COVID-19. As a member of the MERC, MHA CEO Brian Peters joined leaders from the healthcare, labor, higher education and business communities in stressing the need for clearly defined, mandatory standards that govern mask usage, workplace practices, public gathering and certain social activities that can be deployed with discipline. The letter indicates that success in suppressing spread of COVID-19 will maintain the health of Michigan’s economy and support the education of the state’s children.
HHS Revises Provider Relief Fund Usage and Reporting Requirements
The U.S. Department of Health and Human Services (HHS) issued Oct. 22 revised federal Provider Relief Fund (PRF) usage and reporting requirements. These new requirements come on the heels of problematic requirements the HHS issued Sept. 16 that would have resulted in many hospitals being required to return PRF payments to the federal government. The HHS indicated in its announcement that it modified the PRF usage and reporting requirements in response to advocacy efforts by stakeholders, which included efforts by the MHA, the American Hospital Association and others.
The HHS also notes in its reporting document that, if recipients do not expend PRF payments in full by the end of calendar year 2020, they will have an additional six months in which to use remaining amounts toward expenses attributable to COVID-19, but not reimbursed by other sources, or to apply toward lost revenues in an amount not to exceed the difference between 2019 and 2021 actual revenue.
Finally, the HHS revised the definition of “Reporting Entity,” as delineated on Page 2 of the usage and reporting requirements document.
Questions on revised PRF reporting requirements should be directed to Jason Jorkasky at the MHA.
House Republicans Unveil COVID-19 Plan
Michigan House Republicans announced their “Comeback Roadmap” Oct. 20, providing a proposed structure that would govern public health response activities in Michigan. The plan would provide for state level public health orders when COVID-19 cases are high, then delegate those decisions to counties that see lower COVID-19 cases, hospitalizations and positivity rates, among other metrics. The Republicans are expected to introduce legislation to codify this plan in the coming weeks and committee hearings could occur on the proposal thereafter. The MHA will monitor this proposal as additional action is taken. Members with questions may contact Adam Carlson at the MHA.
MDHHS Vaccine Plan Published
The Michigan Department of Health & Human Services (MDHHS) recently submitted its interim draft COVID-19 Vaccination Plan to the federal government.
The plan identifies gaps and lessons learned from the implementation of other vaccines and uses those experiences to improve preparedness for the COVID-19 vaccine. The state will use the 2020-2021 seasonal flu campaign as a full-scale exercise for the COVID-19 vaccine effort.
Under the interim draft, the initial distribution of COVID-19 vaccine will go to critical populations. This includes all people working in a healthcare setting, and hospitals will be among the first to receive vaccine distributions. Vaccine allocation is covered in Section 7 of the plan, which begins on page 32. Section 8 addresses COVID-19 Vaccine Storage and Handling and begins on page 36. Members with questions or comments on the interim draft should contact Laura Appel at the MHA.
Bills Signed to Codify Executive Orders on Liability and Nursing Homes
The governor signed legislation Oct. 22 to codify protections that were originally established in previous executive orders (EOs). House Bill (HB) 6159 is specific to healthcare providers and provides broad liability protections from March 29 through July 14 for healthcare entities and professionals working to respond to the pandemic. The language in this bill closely mirrors the language in subsection 8 from the now-rescinded EO 2020-61. In addition, the governor signed the MHA-supported package of bills (HBs 6030, 6031,6032, 6101) providing broad liability protection to employers that includes further protections to healthcare providers and reinstates many of the provisions in previous EOs, such as language providing quarantine exceptions for healthcare workers.
The governor also signed Senate Bill (SB) 1094 to provide additional guidelines on establishing regional nursing home “hubs” (now referred to as Care and Recovery Centers) and prohibit nursing homes from admitting COVID-19-positive patients without verification of their ability to handle those patients. This bill codifies EO 2020-169, which reflected the recommendations and work of the Nursing Home Task Force. Members with questions on either piece of legislation may contact Adam Carlson at the MHA.
Eligible Facilities May Apply for Designation as Care and Recovery Centers
The MDHHS has moved to a rolling deadline for eligible nursing facilities to apply for the Care and Recovery Center (CRC) designation. Recognizing the limitations that SB 1094 imposes on a hospital’s ability to discharge nursing home residents, hospitals with affiliated nursing homes or networks that include eligible nursing facilities may want to consider applying for the CRC designation.
The purpose of CRCs is to provide care for individuals with confirmed COVID-19 who have not met criteria for discontinuation of Transmission-based Precautions. CRCs operate when hospitals need to discharge residents to manage bed availability and provide an alternative for nursing facilities that do not have the capacity to safely care for residents. Facilities that wish to operate a CRC must have the capacity to designate a distinct area for COVID-19 isolation, be able to dedicate staff to the CRC, and meet other established standards. Specific criteria and other details are available in MSA Policy 20-66 and the CRC operational guidance and protocols. Members with questions on the CRC designation may contact Brittany Bogan at the MHA.
MDHHS Issues EO Updating Nursing Home Visitation Requirements
MDHHS Director Robert Gordon issued an Emergency Order Oct. 21 that updates and further expands requirements for residential care facilities, while also permitting indoor visitation in these facilities in certain circumstances.
Under the order, visitation rules are linked to the risk level of the county and the occurrence of positive COVID-19 cases involving residents or staff within the prior 14 days. Local health departments also can determine that indoor visitation may be unsafe. A health evaluation must be conducted, and some visitors will be required to receive COVID-19 testing prior to entry, while facemasks will always be required. Lastly, visits will be allowed by appointment only and visitors per scheduled visit will be limited to two people or fewer. Members with questions may contact Brittany Bogan at the MHA.
Legislation Advances to Allow Nonclinicians to Order COVID-19 Tests
The Michigan Legislature recently finalized House Bill 6293, which would allow nonclinicians to order COVID-19 tests until June 30, 2021. The legislation codifies the governor’s EO 2020-14, which was in question due to the Oct. 2 Michigan Supreme Court ruling on emergency executive power. The bill now goes to the governor, who is expected to approve it. The MHA supports this important legislation that ensures healthcare providers can quickly and effectively order needed COVID-19 tests and will keep members informed when it becomes law. Members with questions may contact Adam Carlson at the MHA.
Exemption of Michigan Licensure during Time of Disaster
There have been many questions raised about out-of-state healthcare providers since the Supreme Court nullified Gov. Gretchen Whitmer’s extended State of Emergency. Therefore, the MHA worked with the Bureau of Professional Licensing (BPL) within the Michigan Department of Licensing and Regulatory Affairs (LARA) to update the document BPL Clarification: Exemption of Michigan Licensure Time of Disaster, which was originally released March 16.
Per MCL 333.16171 of the Public Health Code, LARA still has the authority to allow out-of-state, Canadian and health providers who have been retired within the last five years to continue to assist during a time of disaster. While the state of emergency has been rescinded, LARA strongly believes COVID-19 qualifies as a disaster and developed updated guidance.
Health systems must keep complete documentation of these individuals, as it must be made available in the event the department receives an official complaint about an individual provider. The MHA has also updated its compliance memo on the topic with the recommendations related to proper tracking. Members with questions should contact Paige Fults at the MHA.
As the coronavirus follows the world into yet another season, the MHA continues to keep members apprised of developments affecting Michigan hospitals during the COVID-19 pandemic through email updates and the MHA Coronavirus webpage. Important updates are outlined below.
Congress Extends Medicare Advance Payment Loan Repayment
U.S. House of Representatives leadership reached an agreement Sept. 22 on a Continuing Resolution to prevent the federal government from shutting down Oct. 1, which also includes two important provisions for hospitals. H.R. 8337, Continuing Appropriations Act, 2021 and Other Extensions Act of 2020,delays until Dec. 11, 2020, previously proposed Medicaid disproportionate share hospital (DSH) cuts. It also delays the deadline for loan repayment of COVID-19-related Medicare Advanced Payments to 12 months from the date an organization received its advanced payments. The language in the bill summary on these two issues states:
Section 2303. Delay of DSH reductions. Section 2303 delays implementation of the allotment reductions for Medicaid disproportionate share hospitals through December 11, 2020.
Section 2501. Medicare Accelerated and Advance Payment Program Changes. Section 2501 extends both the period before repayment begins and the period before the balance must be repaid in full, reduces the recoupment percentage, and lowers the interest rate for payments made under the Medicare Accelerated and Advance Payment Programs and comparable programs between the date of enactment of the CARES Act and the end of the COVID-19 public health emergency.
While the MHA believes the steps taken in the H.R. 8377 are positive, the association will continue to work with the American Hospital Association to urge full forgiveness of the Medicare advanced payments, given the magnitude of the impact COVID-19 has had on hospitals and their patients. Members with questions may contact Laura Appel at the MHA.
HHS Issues Notice on Provider Relief Fund Reporting Requirements
The HHS released a notice Sept. 19 regarding reporting requirements for healthcare providers that received Provider Relief Fund (PRF) payments. This notice includes the categories of data elements that recipients must submit for calendar years 2019 and 2020. It is also a supporting document to its Aug. 14 post-payment notice of reporting requirements. The HHS stated that the reporting system will now be available in early 2021.
According to the guidelines, if recipients do not use all PRF funds by the end of calendar year 2020, they will have six additional months in which to use remaining funds. The funds may be used toward COVID-19 expenses that aren’t reimbursed by other sources or to apply toward lost revenues in an amount not to exceed the 2019 net gain.
The agency indicates these requirements will apply to any provider that received one or more payment totaling at least $10,000. The HHS will make an additional frequently asked questions document available prior to the reporting deadline. The MHA is working closely with the AHA on next steps and will keep members apprised.