To: Mass Senior Care Members
From: Tara M. Gregorio, President
Re: COVID-19 Updates: Interim Financial Report Action Needed by June 19th; CMS Issuing Citations Related to NHSN Reporting Requirements
Date: June 11, 2020
Interim Financial Report – Facilities Need to Designate Individual(s) Who Will Be Filing Report – Registration Required by June 19th
Nursing facilities are required to file an Interim Financial Report by June 30th with EOHHS to account for the manner in which the MassHealth COVID-19 Supplemental Initial Payment for the Up to 50% Program was spent. This program will provide up to $130 million in supplemental funding distributed via four payments. Mass Senior Care has been working with EOHHS in regard to the specific rules that will be in place for facilities to file documentation on the Interim Financial Report Form. EOHHS plans to issue the Accounting Form Template and accompanying FAQ once finalized. In order to streamline and expedite this Interim Financial Reporting, EOHHS will be using the Direct Care Add-on Reporting Portal operated by UMass Medical School (UMASS). At this time, EOHHS is requesting that facilities identify the person or persons who will be filing the interim financial plan for your facility or facilities.
Please complete this form and return to UMASS at NFReporting@umassmed.edu by no later than Friday, June 19, 2020 to register. Once EOHHS finalizes the Interim Financial Form, registered users will be given access to the filing website.
Also note that facilities may use this form to register for the direct care add-on submissions.
Please contact NFReporting@umassmed.edu if you have further questions in regard to registering for filing the Interim Financial Report.
Note that filing the Interim Report timely by June 30th is critical. EOHHS will consider the entire amount of the Initial Payment unspent if the facility fails to submit the interim report timely and it will recoup all funds.
CMS Issuing Citations Related to NHSN Reporting Requirements
Yesterday we were informed by a Mass Senior Care member and today AHCA has confirmed that CMS began issuing 2567s with citations for F884 at F level with a $1,000 per instance CMP to all SNFs flagged by CMS in data transmitted by CDC as not having submitted data or submitting incomplete or otherwise erroneous data for the week of June 1 to June 7. AHCA notes that:
- The notifications are being sent via the CASPER/QIES system (not the normal method for notifying a facility with a deficiency). Thus, facilities must go into their CASPER account to see if they have a citation or not.
- CMS has said a facility can appeal the citation and CMP through the IIDR process by following the steps outlined in the notification letter.
AHCA has implemented advocacy actions with CMS. In the meantime, we recommend the following steps:
- The facility should check CASPER to see if it has a citation
- If the facility has a citation that it believes is in error, it should assemble the information needed to submit an IIDR. We would recommend putting together at least the following:
- A summary table of dates they started the registration process and all dates of communications with CDC/NHSN
- Screen shots if the facility has documented its data submission
- Copies of emails sent and received from CDC/NHSN
- Any other documentation of efforts the facility did to register and submit data such as communications with the QIO or state.