Notify Network of Service Disruptions

The National Weather Service is warning people in North-Central Montana that the far-below-zero weather there, expected to continue through at least 13 February, can frostbite exposed skin in as little as five minutes. For details and more accurate location information, click HERE.

NWS is also warning about relatively heavy snow in the Puget Sound region through at least 13 February, making travel “very difficult to impossible.” For details about the North and Central Sound, click HERE, and for details about the South Sound, Hoods Canal, and the Chehalis Basin, click HERE. Weather conditions seem to be improving in Southwest Washington and Northwest Oregon, but snow, and ice-storms in the usual locations, have been making travel “challenging” and are still possible; click HERE for details. Click HERE for details about the area around Salem.

CMS requires ESRD Networks to track the status of facility operations and patient access to treatment during emergency events at all facilities, including disruptions due to wildfire, excessive heat or cold, water pollution, stormy weather, or any other natural or man-made event that interrupts your normal schedules. If the operations of your facility, or ability for patients to have access to dialysis, are impacted by emergency events, please let your Network know right away.

For Washington, Oregon, Idaho, Montana, and Alaska (Network 16), call Brianna Smith at 206-923-0714 or email BSmith2@Comagine.org. We also ask that you fill out and submit the Network Disaster Reporting Form at http://www.esrdnetwork18.org/machform/view.php?id=44393. (Network 18 will forward the completed form back to Network 16.)

In Southern California (Network 18), call Brianna Smith at 206-923-0714 or email BSmith2@Comagine.org, and fill out the form at http://www.esrdnetwork18.org/machform/embed.php?id=16298.

Never put PHI or PII in an email or online form. Examples include patient name or initials, birthdate, SSN, and other identifying information.

Involuntary Discharge/Transfer Requirements

CMS Conditions for Coverage (CfC) require all facilities to notify both their ESRD Network and their State Survey Agency of all involuntary discharges or transfers, within specified time parameters. 

If you’re considering an involuntary discharge or transfer in Network 16, first contact Network Patient Services Coordinator Lisa Hall at lhall@nw16.esrd.net or 206-923-0714. Lisa may be able to help you negotiate a better outcome. Also follow the instructions found under “Notifying the Network” on https://www.nwrn.org/providers-and-professional-staff/patient-services/ivd.html.

For Network 18 facilities, follow the instructions under “Preventing & Reducing Involuntary Discharge” on http://www.esrdnetwork18.org/providers/patient-services/.

Emergency Exercise Exemptions

CMS has updated the Emergency Preparedness Testing Exercise Requirements to accommodate industry impacts from COVID-19, exempting a facility that activates its emergency plan to deal with a real emergency (such as COVID-19) from having to complete the subsequent full-scale community-based exercise or individual facility-based functional exercise. To qualify for the exemption, a facility must complete written documentation of their emergency plan activation. CMS and State Survey Agencies can request a copy of this documentation during survey and certification reviews. Facilities can provide this documentation by completing an After-Action Report (AAR) following the actual emergency.

Information on how to create an AAR can be found in the Network LMS Emergency Preparedness Resource Book or at https://www.kcercoalition.com/en/events/2020/july-2020/dialysis-facilities-the-basics-of-preparing-an-after-action-report-for-an-incident-or-disaster/ .

Find an AAR template at https://s3-us-west-2.amazonaws.com/nwrn.org/files/LMS-O/KCER_Dialysis+Facility+Incident+AAR_FINAL.pdf .

The updated Emergency Preparedness Testing Exercise Requirements can be found at https://www.cms.gov/files/document/qso-20-41-all.pdf .

If you have any questions or need assistance completing the requirements for the exemption, contact your Network.

Notify Network of Service Disruptions

CMS requires ESRD Networks to track the status of facility operations and patient access to treatment during emergency events at all facilities, including disruptions due to wildfire, excessive heat, water pollution, or any other natural or man-made event that interrupts your normal schedules.  If the operations of your facility, or ability for patients to have access to dialysis, are impacted by emergency events, please let your Network know right away.

For Washington, Oregon, Idaho, Montana, and Alaska (Network 16), call Lisa Hall at 206-923-0714 or email LHall@Comagine.org.  We also ask that you fill out and submit the Network Disaster Reporting Form at http://www.esrdnetwork18.org/machform/view.php?id=44393.  Network 18 will forward the completed form back to Network 16.

In Southern California (Network 18), call Brianna Smith at 206-923-0714 or email  BSmith2@Comagine.org, and fill out the form at http://www.esrdnetwork18.org/machform/embed.php?id=16298.

Never put PHI or PII in an email or online form.  Examples include patient name or initials, birthdate, SSN, and other identifying information.

7/16 KCER After-Action Report Webinar

KCER will present a July 16, 2020 webinar for dialysis facilities on The Basics of Preparing an After-Action Report for an Incident or Disaster.  The webinar presents KCER’s template for After-Action Reports (“AAR”) and includes instructions for meeting the CMS Emergency Preparedness Rule for dialysis facilities, and specific guidance for AARs on your response to COVID-19.  Find more information in the flyer below.  Click HERE to register.  Contact KCER at kcerinfo@hsag.com for questions or assistance.

An AAR describes an event or process that for any reason you needed or wanted to respond to or improve, how you responded, your evaluation of the effectiveness of your response, and any improvements you recommend for “next time,” or to complete or enhance your response to the current issue.

HDC on Safe Social Work and COVID-19

Home Dialysis Central has published a blog post on Dialysis Social Work During a Pandemic: Caring for Patients Safely, thoroughly reviewing what are permitted and required by:

  • CMS Conditions for Coverage,
  • Social Work licenses and training,
  • Medicare reimbursement rules and waivers,
  • Patient and staff safety,
  • Home dialysis,
  • Effective communication,
  • PPE,
  • Telehealth,
  • Comparative advantage,

all in the context of the COVID-19 pandemic.  Find the post at https://homedialysis.org/news-and-research/blog/361-dialysis-social-work-during-a-pandemic-caring-for-patients-safely.

5/26+ CMS Shareholder Engagement Calls

CMS is hosting weekly Stakeholder Engagement sessions to share information related to the agency’s response to COVID-19.  These sessions are open to the healthcare community and provide updates, share best practices, and offer attendees an opportunity to ask questions of CMS and other subject matter experts.  Conference lines are limited so we encourage you to join via audio webcast on your computer or smartphone web browser.  You are welcome to share this invitation with your colleagues and professional networks, but these calls are not intended for the press.  Call recordings and transcripts are posted on the CMS podcast page at: https://www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums/PodcastAndTranscripts.

Targeted Updates for Dialysis Organizations on the agency’s latest COVID-19 guidance, also featuring leaders in the field sharing best practices, with an opportunity to ask questions if time allows.  Wednesday May 27, 2020, 2:30-3:00 pm PDT, toll-free 833-614-0820, passcode 6152699, audio webcast link https://engage.vevent.com/index.jsp?eid=5779&seid=2123#/main/simplify.

COVID-19 Office Hours Calls are an opportunity for providers to ask questions of CMS officials about temporary actions that allow increased capacity, expanded workforce, patient priority, and telehealth.  Tuesday May 26, 2020, 2-3pm PDT, toll-free 833-614-0820, passcode 8977438, audio webcast link https://engage.vevent.com/index.jsp?eid=5779&seid=2012#/main/simplify.

Lessons from the Front Lines with representatives from CMS, FDA, and the Coronavirus Task Force, along with front-line clinicians.  Friday May 29, 2020, 9:30-11:00 am PDT,  toll-free 877-251-0301, passcode 6350189, audio webcast link https://engage.vevent.com/index.jsp?eid=5779&seid=2075#/main/simplify.

6/1 Comments Due on CMS Flexibility Rules Change

CMS has published an Interim Final Rule with Comment Period on the Flexibility changes in Medicare rules made on March 31, 2020.  The Comment Period will expire June 1, 2020.  For details and comment see Medicare and Medicaid Programs: Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency at https://www.regulations.gov/document?D=CMS-2020-0032-0013.

CMS Summary of COVID-19 Waivers as of 4/9

On April 9, 2020 CMS published a document on COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers, summarizing relief during the current emergency from normal requirements, with the intention to allow healthcare facilities to focus more attention on treating COVID-19 patients.  Waivers for dialysis facilities are summarized on pp.17-19, and include adjustments to regulations for water quality testing, fire inspections, patient assessments, plan of care, rounds, home visits, special purpose facilities, PCT certification, transferability of professional credentials, dialysis in nursing homes, and many other details.  Find the document at https://lnks.gd/l/eyJhbGciOiJIUzI1NiJ9.eyJidWxsZXRpbl9saW5rX2lkIjoxMDEsInVyaSI6ImJwMjpjbGljayIsImJ1bGxldGluX2lkIjoiMjAyMDA0MTAuMjAwMTg1NTEiLCJ1cmwiOiJodHRwczovL3d3dy5jbXMuZ292L2ZpbGVzL2RvY3VtZW50L3N1bW1hcnktY292aWQtMTktZW1lcmdlbmN5LWRlY2xhcmF0aW9uLXdhaXZlcnMucGRmIn0.NmtjnP-P1fvfNYld0nlhqMouY3FZb10Xx7Aull2AIwA/br/77281657281-l.

Notify Network of Service Disruptions

CMS requires ESRD Networks to track the status of facility operations and patient access to treatment at all facilities. If the operations of your facility, or ability for patients to have access to dialysis, are interrupted for any reason, let your Network know as soon as possible.

In Washington, Oregon, Idaho, Montana, and Alaska (Network 16), fill out and submit the Network Disaster Reporting Form at http://www.esrdnetwork18.org/machform/view.php?id=44393 (the completed form gets routed back to Network 16).  If you need assistance, you may also call or email Lisa Hall at 206-923-0714 or LHall@Comagine.org, or Brianna Smith at 509-306-8313 or BSmith2@Comagine.org.

In Southern California (Network 18), fill out and submit the Network Disaster Reporting Form at http://www.esrdnetwork18.org/machform/embed.php?id=16298.  If you need assistance, you may also call Eileen Rhodes or Anabel Galindo-Guerrero at 888-268-1539, or email them at ERhodes@Comagine.org or AGalindo-Guerrero@Comagine.org.

Never put patient name, initials, address, birthdate, SSN, other identifying information, or any other PHI or PII, in an email or online form. If PHI or PII is important in this context, call instead.