September Nursing Home Infection Control Payments: HHS has informed LeadingAge that the second portion of the September payment (an additional $80+M) will begin going on out on Monday, Nov. 30 to 8,925 nursing homes.  We have not received any information as to which nursing homes will be receiving this payment.  This is based off of the nursing home’s mortality performance.

You will recall the September mortality portion of the payment was delayed as HHS tried to collect additional mortality data from nursing homes beyond what is reported on NHSN . HHS has concluded based upon its minimal success in obtaining additional information on September mortality, that going forward they will use total fatalities for the performance period instead of trying to discern between deaths of residents due to COVID admissions vs. in-facility infections. Apparently, what they have observed through the data is that those nursing homes with a high proportion of COVID admissions to in-facility infections have a lower mortality rate on average. Therefore, the reason for seeking to breakdown the information no longer seems necessary  The updated Nursing Home Infection Control incentive payment methodology can be reviewed here.

In addition, HHS indicated it will soon publish the facility-level detail about the September payments on the Provider Relief Fund website that LeadingAge has been asking for. This should help those organizations with multiple nursing homes know how to distribute the funds.

Missing September Nursing Home Infection Control Payments: LeadingAge has compiled a list of roughly 70 member nursing homes that believe they met the program’s gateway criteria for the incentives but did not receive an incentive payment. LeadingAge had previously sent a list of 45 nursing homes to HHS to review. They responded late last week suggesting that the nursing homes had incomplete data in NHSN for some portion of not only the 4-week performance period but the 6 weeks prior. Nicole Fallon from LeadingAge National has asked these nursing homes to double check their entries. What we are hearing from some of these members is that either: 1) all their NHSN data is complete; or 2) their data was marked complete when it was entered but now shows incomplete in NHSN for dates in August.  This incomplete data issue may correlate to NHSN updates made to the data to include antigen testing. The update took place on Thursday, August 27. This may have resulted in some nursing homes appearing to have not submitted complete data. This issue will be raised with HHS in an effort to see if HHS will issue September incentive payments to these 70 nursing homes, as they were not required to answer these questions at the time of data submission.  

All nursing home members should review their NHSN data to ensure that all entries are complete and accurate. In addition, HHS also notes in its new methodology document that it is using MDS assessment data for risk adjusting the mortality measure and if that information is incomplete, HHS will assign the lowest possible score to a nursing home. Therefore, both of these items can impact a nursing home’s infection control incentive payment both eligibility for future payments as well as amount received.

October Incentive: Given the new methodology on mortality, HHS anticipates being able to distribute the October payments more quickly.  The good news is that early indicators are that nursing homes are still outperforming their communities on infection rates even though cases went up in October. Therefore, HHS expects to be able to distribute a larger incentive payment in October. Remember up to $400M per month in incentive payments. No word on the timing of these payments coming out.

Actions required related to Infection Control Incentive Payments: Finally, providers who receive an incentive payment have 90 days to attest to the payment using the attestation portal and must use these funds for Infection Control expenses as specified under the Terms & Conditions for the NHIC Distribution. Providers must attest every time they receive a Provider Relief Fund payment. Providers can opt to reject these payments as well.

Questions?

Contact:

David Carter | Director, Health Care Finance & Policy

C 360.888.5702