Top Ten List: Justify Your Skilled Nursing Facilities (SNF) COVID-19 Expenses

This blog was written and produced by Kathleen Angelone, Healthcare Consulting Principal at The Bonadio Group. Looking to get in touch with Kathleen? Reach out today: kangelone@bonadio.com.

You’ve received your CARES Act funds. Now, what do you have to do to keep it? All of the CARES Act Provider Relief Fund money and Payroll Protection Program (PPP) funds will not have to be paid back if you use it on allowable expenses. PPP will cover payroll expenses, rent, mortgage, and utilities. The CARES Act will cover all unreimbursed COVID-19 expenses and lost revenue.

The key to managing this process will be record-keeping and documentation. Segregate all your expenses now so you will have the information later for audit and cost reporting—see My Top Ten list below on suggested ways to do this.

(Remember that expenses cannot be duplicated when justifying funds spent. CARES Act funds will only cover expenses NOT reimbursed through other programs including PPP).

My Top Ten List: Document and Segregate Your Expenses

1. PPE – Clinical PPE including additional supplies for increased use, as well as increased prices due to shortages and time spent searching for PPE. Also included in this is the additional resident assessment and all of the costs associated with isolating them, contributing to increased documentation, additional clinical equipment and supplies, time spent on telehealth issues, and CMS/CDC infection control procedure changes.
2. Testing Costs – COVID-19 personnel testing costs associated with Executive Order 202.30 mandating twice-weekly testing for all nursing home personnel. Including test kits, supplies, lab work, time spent scheduling, reviewing and managing the testing process, and incentives paid to employees to encourage testing and compliance.
3. Employee Expenses – This includes additional hours for screening, coverage (including contract) of absent employees, development of additional policies, increased scheduling, employee perks such as gift cards and meals, additional education, moving of staff where needed.
4. Administration Costs – Such as those associated with updating policies, managing an anxious workforce, communication to both staff and families, time spent hiring and managing an absent workforce, management of COVID-19 exposure in your facility and phone time working through new rules and problem resolution as a result; compliance, consulting fees for COVID-19 response assistance, maintaining records of daily events, and/or public relations.
5. IT and Equipment – This includes additional equipment, software, and internet upgrades, to accommodate remote work, video conferencing, and virtual family visitation.
6. Finance – Time spent applying for grants/loans, reporting compliance, development of new policies and procedures, consulting fees for COVID-19 response assistance, billing time and issues with lab tests, and 1135 waivers.
7. Lost Revenue – Due to lower/refused admissions, reduced therapy services, closed programs such as outpatient services, and adult day care programs.
8. Equipment – Security and PO&M equipment to test temperatures of all personnel, vendors, etc. who enter the building, as well as the staff who manage people in the building. Plus, the additional cost of waste services due to enhanced infection control and increased PPE.
9. Patient Food Service – Meals in isolation, meals in rooms, the additional cost of staff to assist with meals, and/or additional equipment due to meals served in a social distancing environment.
10. Additional Staff Hours – This includes housekeeping and the need for more intense cleaning and sanitizing, additional activities due to more individualized activities, as well as additional time for admin, nursing, finance staff who spent time spent handling additional duties and virus issues, as well as communicating with families who cannot visit their loved ones and need help to talk to them through phone calls or window visits.

For further information or for assistance with expense record-keeping and documentation, please contact Kathleen Angelone or Janine Mangione.

The information and advice we are providing for this matter relates to COVID-19 legislative relief measures. Because legislative efforts are still ongoing, we expect that there may be additional guidance and clarification from regulators that could modify some of the advice and information provided to you, after the conclusion of our engagement. We, therefore, make no warranties, expressed or implied, on the services provided hereunder.