Updated from 3/14/20
15 Jun 2020
Updated June 15, 2020
ODP has indicated that they are seriously considering issuing FY 19-20 funding levels equal to reported costs in lieu of reviewing the pending FY 19-20 waiver requests and forthcoming waiver requests for COVID-19 expenses. They have stated that this will be "standard interim rate methodology," regardless if you received the advanced funding, known as "COVID Waiver Requests for Immediate Funding."
If ODP does establish rate setting via the review and approval of waiver requests, they have stated that they will allow COVID-19 related waiver requests until July 31 st. As of today's date, ODP is not answering the question about how rate setting will be done.
Further, ODP has indicated that COVID-related expenses will have to be documented in the ID46 cost report. They have not answered any questions as to how this will be done--whether it is one additional schedule, or multiple revised schedules. They have not indicated whether the COVID expenses will be identified separately as supplemental information, or whether all costs will have to be segregated within the cost report.
As described below, it is important to track all expenses related to COVID so that you are able to pull what is needed when we find out how it is to be reported to ODP.
AZTAC has had several discussions with providers regarding the submission of waiver requests for costs associated with the impact of the Coronavirus. Obviously, the situation across the Commonwealth is evolving day to day, and no one is sure how long or how severe the impact will be. As you are primarily focused on the care of the people you serve and doing everything to meet their individual needs, I wanted to remind you that it is also important to monitor the associated costs that might increase during a pandemic.
Fortunately, the ICF/ID program has a longstanding regulatory process by which you can request additional funding for such increased costs. To my knowledge, ODP has not made any formal announcements about this issue as of this date; however, the existing regulations for rate setting already apply, and you have a pathway for additional funding if needed.
Now is the time to be sure you are tracking these costs. Following are some suggestions to think about in case you need to submit a request for a waiver (of the standard interim rate) for additional funding. Documentation is very important toward receiving approval of your request.
- Keep a list of all new or increased expenses that are incurred; keep receipts; set up a special folder or file drawer
- Keep a daily log or a journal in each home to document any instances related to the virus, cost related or not
- Assign someone "in charge" of knowing what the increased costs are, so they can be properly documented to your fiscal team
- Consider capturing costs in a separate account so you can monitor the impact
- Keep track of changes in staffing, such as increased hours and/or increased overtime
- Record the number of people calling off work because they are sick or must stay home for other virus-related issues.
- Keep track of additional needs because individuals are in the home rather than at day program or other various events
- Record the specific dates that services, such as day program, are canceled.
- Monitor fluctuations in hospital days and therapeutic leave days
Having all of your information well documented and compiled in one place will 1) enable you to determine if you need to submit a request; and 2) the information will enable you to clearly describe the issues, your efforts, and the costs in your narrative justification. If you submit a waiver request for additional funding, you will need to document your costs both before and after the impact of the coronavirus. You will only be able to ask for the increase in costs, not necessarily the full costs, above and beyond what you are already funded for.
A few examples to think about ….
- You do not have to know or serve anyone who has contracted the virus to be fiscally impacted by the social changes
- If your own staff typically cleaned the home previously, but now you are bringing in professional cleaners once per week for deep cleaning and disinfecting. Or perhaps you had professional cleaning once per month, and now you are doing that weekly.
- If you are purchasing significantly more supplies than previously, how would you document the costs before and after the impact of the virus? Supplies can be very tedious to document, such as cleaning supplies, masks, gloves, etc.
- Perhaps you are experiencing a significant amount of overtime, because staff are calling off due to illness or perhaps to stay home with their children now that schools are closed. Your payroll reports will be needed to document the increased hours and/or overtime costs, and we will need to compare the data to what is currently approved in your ODP approved budgets.
- Did you have to purchase or replace any equipment, such as air purifiers, computers, software?
- Are there any increased expenses associated with telemedicine, such as new software or equipment?
- Did any of your existing contracted services or products increase in cost due to supply and demand or availability?
- Have you pursued any alternatives for covering increased costs, such as insurances?
- Have you reported any incidents related to the Coronavirus?
- Has the Department of Health cited you for anything related to the Coronavirus?
- Did you incur any costs to set up a quarantine area?
- Do you need to provide additional training, counseling, or nursing services--to your consumers or staff?
- What is your organization's policy for paid time off, and was it revised, due to the pandemic?
- Are your employees paid while not at work due to self-quarantine?
- Federal regulations already exist regarding requirements for infection control, so some actions and costs may not necessarily be above and beyond normal requirements you already had in place. (42 CFR 483.470 (l) Infection control)
Once you have determined an increase in costs, do you still need to submit the request, or can you absorb those costs within your current funding? Do you know what your estimated FY 2019-20 funding is (even though ODP has not issued FY 19-20 rate setting yet), and how does that compare to your projected expenses in total?
Finally, be aware that the waiver submissions must be submitted during the fiscal year to which they apply. So FY 2019-20 submissions must be submitted before the end of this fiscal year, and if the impact continues beyond July 1, you will need to submit another submission for FY 2020-21. As always, you should submit your request as soon as you are able.
Hopefully, the fiscal impact on your programs will be minimal, and you will be able to absorb any increased costs that occur; however, if you monitor costs closely now, it will be easier to document later, if indeed you need to request additional funding.
Contact Mary Anne at firstname.lastname@example.org if you would like to discuss further, and we will be glad to assist you.