Virginia Network of Private Providers
Provider Call
April 3, 2020
Topic – Federal Action
• FFCRA (Families First Coronavirus Relief Act)
o As we shared on 3/31 – DOL FAQ #56 seems to answer the question about whether our staff are considered “health care workers”
o You will need to work out, in consultation with your attorney, how to handle this exemption and it will be extremely tricky if you do not already have a paid leave policy.
o You will need to decide how to handle leave if a staff member needs to self-isolate, or becomes ill, or clearly has a direct exposure
o And while there is no “Notice” Requirement if you claim exemption for all of your employees, it may be prudent to explain what and why in writing!
• CARES ( Coronavirus Aid, Relief and Economic Security)
o Codifies the legislation to permit Medicaid to pay for DSPs supporting individuals in the hospital – this will take some time. It is unlikely that this will be in the Appendix K and after the “emergency” it will need to be an amendment to all three of the Waivers
o Adds unemployment benefits – both more money and an extension; remember that unemployment is still payment for individuals who are “unemployed!” We have confirmed with VEC that they are still following their process to confirm each claim, but final adjudication will take far longer than usual.
o You have every reason, however, to tell an employee who is just going to walk away from available work, that you will dispute their claim and when adjudicated, they may be subject to a payback of all monies collected.
o We also have confirmed that the $1,200 “stimulus check” will not be counted as income for Medicaid Purposes!
o AND the IRS has reversed it’s position on the requirement for an SSA recipient to file a “simple tax return” – however, SSI recipients will still need to file; we are waiting for the form!
Topic – Virginia Action
• About that “glitch!”
o "DMAS and DBHDS have implemented an allowance for those per diem residential services constrained by the 344 days per ISP year to continue to bill during the two month service authorization extension without penalty. Providers should continue to submit ISP/PFS renewals as they are due; however, Service Authorization staff will authorize these from the end date of the automatic extension to the end date of the annual ISP."
• We are still waiting for the 1135 and the Appendix K, but there is movement!
• There is a second Medicaid Memo with some clarifications and some additions specifically related to BH and ARTS
• We are getting updated FAQs from Licensing on a regular basis (3/25) and the DD Q&A (spreadsheet) on a regular basis (update scheduled for today). FYI – the spreadsheet is linked inside the FAQs!
• There was an alert about some guidance documents which are out for comment – but not actually posted until 27 April! We’ll remind you at the time!
• And the proposed Licensing regs are moving forward – these are the ones about Risk Management, RCA and Incident Reporting – we have a way to go yet! Both are DOJ topics . . .
Topic – VNPP
• We have established the Job Board and have added BH providers; we will add the ones that we have that filled out the form already and hope that others join in!
• Survey for Damage Control!
Questions from this week –
• Others from the stack of emails
Questions from the chat box
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