Nursing Home Infection Control Distribution

What is the Nursing Home Infection Control distribution?

The Nursing Home Infection Control (NHIC) distribution is a component of a Provider Relief Fund (PRF) Targeted Distribution (formally known as the Skilled Nursing Facility and Nursing Home Infection Control Distribution) awarded to skilled nursing facilities and nursing homes nationwide to help combat the devastating effects of this pandemic.

In addition to direct payments to providers, this Distribution included an incentive payment structure called the Quality Incentive Payment (QIP) Program and provided more funding to nursing homes and skilled nursing facilities based on certain performance measures. These payments may only be used for the infection control expenses defined in the Terms and Conditions and may not be used to reimburse lost revenues.

What is the Quality Incentive Payment (QIP) Program?

The QIP Program provided additional funding to nursing homes and skilled nursing facilities based on their performance measured on two outcomes.

• COVID-19 infection performance measure: To evaluate the infection performance measure, HRSA compared a facility infection rate with the COVID-19 infection rate in their county. The infection rate criterion excluded facilities with an infection rate greater than their county infection rate.
• COVID-19 mortality performance measure: The mortality performance measure quantified how facilities with COVID admissions and in-facility infections performed relative to an expected level of mortality, given their total number of infections and the demographic characteristics of their residents. The mortality rate criterion excluded facilities that performed below benchmark levels on the rate of mortality among residents that contracted COVID in the facility or were admitted to the facility with COVID.

Under the QIP Program, payment calculations relied on self-reported data submitted by facilities to the CDC’s National Healthcare Safety Network (NHSN) COVID-19 Long Term Care Facility Module. For additional information see the methodology documents: Nursing Home Quality Incentive Program Methodology Rounds 1 and 2 (PDF) and Nursing Home Quality Incentive Program Methodology Rounds 3 and 4 (PDF).

What was QIP payment schedule?

There were four performance periods in September, October, November, and December 2020, for which funds were distributed between November 2020 and February 2021.

What were the performance periods of QIP Program?

The performance periods were as follows:

While the performance periods were mostly limited to four-week blocks, the alignment of NHSN reporting weeks results in October containing five weeks of data. For reference, the performance period referred to the four-week period during which infection rates and death counts were totaled up. However, in order to accurately measure mortality rates, we looked at the count of infections in an infection exposure window that covered the performance period and the six preceding weeks.

NHIC reporting

What needs to be reported?

The recipient will report on the use of NHIC payments associated with the following infection control expenses as outlined in the Terms and Conditions:

• Costs associated with administering COVID-19 testing
• Reporting COVID-19 test results to local, state, or federal governments
• Hiring staff, whether employees or independent contractors, to provide patient care or administrative support
• Providing additional services to residents, such as technology that permits residents to connect with their families if the families are not able to visit in person
• Other expenses incurred to improve infection control, including activities such as implementing infection control “mentorship” programs with subject matter experts or changes made to physical facilities
• PRF recipients that received only NHIC payments will not report on lost revenues. Per the Terms and Conditions of payment, NHIC payments may not be used to reimburse lost revenues.
• The interest earned on Nursing Home Infection Control Distribution payments must be reported separately from interest earned on other PRF payments

Recipients may use NHIC payments for eligible expenses to prevent, prepare for, and respond to coronavirus. The recipient must not use NHIC funds to reimburse expenses that have been reimbursed from other sources or that other sources are obligated to reimburse. The reporting entity will report expenses by calendar year quarter. Calendar year quarters are defined as follows:

• Quarter 1 (Q1): January 1 – March 31
• Quarter 2 (Q2): April 1– June 30
• Quarter 3 (Q3): July 1– September 30
• Quarter 4 (Q4): October 1 – December 31

Reporting Entities that received between $10,001 and $499,999 in aggregated PRF payments during the Payment Received Period are required to report by calendar quarter on the use of Nursing Home Infection Control Distribution payments in two categories:

1. General and Administrative Expenses and
2. Healthcare Related Expenses

Reporting Entities that received $500,000 or more in aggregated PRF payments during the Payment Received Period are required to report by calendar year quarter on the use of NHIC payments in greater detail within the two categories of General and Administrative Expenses and Healthcare Related Expenses. The reporting includes the following sub-categories of expenses:

1. General and Administrative Expenses
   1. Mortgage/Rent: Payments related to mortgage or rent for a facility specifically for infection control.
   2. Insurance: Premiums paid for property, malpractice, business insurance, or other insurance relevant to operations for infection control.
   3. Personnel: Workforce-related expenses as outlined in the Terms and Conditions such as personnel costs associated with administering COVID-19 testing; reporting COVID-19 test results to local, state, or federal governments; hiring staff to provide patient care or administrative support; providing additional services to residents; workforce training; and mentorship programs to improve infection control; or other personnel costs incurred for infection control. Staffing, including temporary employee or contractor payroll and overhead employees, is included.
   4. Fringe Benefits: Extra benefits supplementing an employee’s salary, which may include hazard pay, travel reimbursement, and employee health insurance. May only be charged in proportion to salary costs for infection control.
   5. Lease Payments: New equipment or software leases, fleet cars, and medical equipment that is not purchased and will be returned to its owner, so long as it is used for infection control.
   6. Utilities/Operations: Lighting, cooling/ventilation, cleaning, or additional third-party vendor services not included in the “Personnel” sub-category and whose purpose is for infection control.
   7. Other General and Administrative Expenses: Expenses not captured above that are for infection control and generally considered part of general and administrative expenses.
2. Health Care-Related Expenses
   1. Supplies: Expenses paid for purchase of supplies (e.g., single use or reusable patient care devices, cleaning supplies, office supplies, etc.) used for the purpose of infection control during the period of performance. Such items may include personal protective equipment (PPE), hand sanitizer, and supplies for patient or staff COVID-19 testing, or expenses associated with distribution of a COVID-19 vaccine licensed or authorized by the Food and Drug Administration.
   2. Equipment: Expenses paid for purchase of equipment used for infection control, such as updates to HVAC systems or sanitizing equipment.
   3. Information Technology (IT): Expenses paid for IT or interoperability systems to expand or preserve infection control during the reporting period, such as telehealth infrastructure, increased bandwidth, technology that permits residents to connect with their families, and teleworking to support remote workforce.
   4. Facilities: Expenses such as lease or purchase of permanent or temporary structures, or to retrofit facilities to accommodate revised patient treatment practices to support infection control during the period of performance.
   5. Other Health Care-Related Expenses: Expenses not captured above that are for infection control and are health care-related expenses.

What is the reporting process?

• When reporting the use of NHIC payments, PRF recipients will submit a consolidated report that distinguishes the use of NHIC payments for expenses separately from other General and Targeted Distribution payments.
• NHIC payments (including QIP) is a PRF Targeted Distribution with associated Terms and Conditions. The original recipient of a Targeted Distribution payment is always the Reporting Entity.
• A parent entity may not report on its subsidiaries’ Targeted Distribution payments. Recipients who received one or more PRF payments (including any NHIC payments) exceeding $10,000 in the aggregate during a Payment Received Period are required to report in each applicable Reporting Time Period by using the PRF Reporting Portal.

What are the reporting deadlines?

PRF recipients must only use payments for eligible expenses including services rendered during the Period of Availability, as outlined in Table 2 below. The Period of Availability of funds is based on the date the payment is received. The payment is received on the deposit date for automated clearing house (ACH) payments or the check cashed date. Providers must follow their basis of accounting (e.g. cash, accrual) to determine expenses.

Recipients who received one or more payments exceeding $10,000 in the aggregate during a Payment Received Period are required to report in each applicable Reporting Time Period as indicated in Table 2. Reporting must be completed and submitted to HRSA by the last date of the Reporting Time Period. PRF recipients that do not report within the respective Reporting Time Period are out of compliance with payment Terms and Conditions and may be subject to repayment and/or debt collection.

*Grace period ended on November 30, 2021.

PRF recipients may use payments for eligible expenses incurred prior to receipt of those payments (i.e., pre-award costs) so long as they are to prevent, prepare for, and respond to coronavirus.

However, HRSA expects that it would be highly unusual for providers to have incurred eligible expenses prior to January 1, 2020.

Need help?

Resources available to Reporting Entities:

• HRSA hosted a Technical Assistance Session for providers required to report on Nursing Home Infection Control Distribution Payments.
  • Download the slides (PDF - 1 MB)
• Targeted Distribution-specific FAQ
• Download all Provider Relief Fund FAQ (PDF - 376 KB)
• Provider Support Line 866-569-3522; for TTY dial 711. Hours of operation 8 a.m. – 8 p.m. CT, Monday through Friday. Hours are subject to change.