Yes, the EEOC released vaccine guidance in December which confirmed that employers can mandate COVID vaccines. The guidance also included a number of cautionary reminders related to penalties for implementing mandatory policies, that restrict the rights of staff who meet certain exemptions categories (i.e. religious & disability). Additional guidance is available through the EEOC FAQ (scroll to the bottom for guidance on vaccine policies on the workplace, specifically section K.1).

Regardless of health insurance status, California has waived all costs associated with the screening, testing, and vaccination of COVID-19. If employers require testing or vaccination, they must pay for the time it takes to obtain either, including travel time. 

Yes, as a condition of employment. Like existing employees, new hires should be provided a reasonable accommodation if they present a written Medical or Religious exemption. If qualified for the exemption, they are subject to the weekly testing order. The August 3rd AFL does mention verification of vaccine status of new hires, “Health care facilities should continue to implement strategies to increase and maintain vaccination coverage among HCP as high as possible, including verifying vaccination status of new hires”.

Facilities have multiple options to verify vaccine status. See CDPH’s guidance for vaccine record guidelines and standards.

For more information about the state’s COVID-19 vaccination plan, visit the California Department of Public Health’s COVID-19 webpage.  

Enrollment in the California COVID-19 Vaccination Program requires providers to be credentialed/licensed in the jurisdiction where vaccination takes place; complete all required training; and comply with federal and state requirements.

CDPH developed this guide, which outlines key tasks and available resources to help providers onboard to the COVID-19 Vaccination Program.

COVIDreadi was the portal to apply for enrollment in the federal COVID vaccination program. Starting January 11, 2021, California is transitioning the enrollment process to CalVax.

MyCaVax is a state-wide centralized system for health care providers enrolled or interested in participating in the California COVID-19 Vaccination Program. The MyCaVax platform provides a system to manage vaccine enrollment, ordering, inventory, administration, reporting and data analytics. Office hours and training materials such as job aids, videos, and recorded demos will be available to support all system users as they navigate through the MyCaVax platform.

Health centers are currently eligible to enroll in MyCaVax.

Please send your inquiries to CDPH at covidcallcenter@cdph.ca.gov.

Local health departments determine Provider eligibility and allocation of the COVID-19 Vaccine. With the current vaccine supply very limited, they are working diligently to allocate COVID-19 Vaccine doses to Providers as they become available. For daily updates on doses shipped and administered, visit CA Department Public Health at COVID-19 Vaccine Doses.

Once their location is approved, COVID-19 Vaccine Providers can submit COVID-19 Vaccine order requests through MyCaVax. Note, that once an order is submitted, it cannot be changed. Once allocation is approved, Providers will receive a first notification from noreply@agreeya.com. A second notification of order processing will alert providers to expect COVID-19 Vaccine shipments within 24 to 48 hours of the notice.

Currently, the MyCaVax system is programmed to reflect manufacturer specific cold storage requirements and will not allow orders to be placed without the required storage units.

Providers can request COVID-19 Vaccine from a specific manufacturer when ordering through MyCaVax. However, a selected choice is not guaranteed as COVID-19 Vaccine Provider storage capacities are considered and local health departments determine allocation.

It is anticipated that ancillary supplies will be provided for all phases of the COVID-19 Vaccine. Ancillary supplies will be packaged in kits and will be automatically ordered in amounts to match vaccine orders and shipped to the provider. Because of cold chain requirements, kits will ship separately from vaccine but should arrive before or on the same day as the vaccine.

Kits will include needles of various sizes for the population served, syringes, alcohol prep pads, surgical masks, face shields for vaccinators, COVID-19 vaccination record cards for vaccine recipients, vaccine needle length and guide, and diluent and mixing supplies based on the vaccine product. Ancillary kits will not include N-95 masks, sharps containers, gloves, or bandages.

Within 24 hours of administering a dose of COVID-19 Vaccine Providers must:

1. Report COVID-19 doses administered to your local immunization registry (e.g., CAIR2, Healthy Futures, or SDIR).
2. Submit race and ethnicity information for every vaccinated patient.
3. Report COVID-19 vaccine doses in inventory daily to the VaccineFinder website. Additional information is available in the COVID-19 Vaccine Reporting Requirements.

California COVID-19 Vaccination Program Providers who are not complying with the requirement to submit doses to their local Immunization Information System (IIS) within 24 hours of administration, may result in the clinic’s expulsion from the California COVID-19 Vaccination Program. If you have unreported COVID-19 doses administered, make every effort to enter them into your local IIS immediately and bring your clinic into compliance.

Per CDPH: All vaccinations must be recorded in CAIR (or local IIS) within 24 hours. It can be a daunting task to upload many records individually. To ease the burden, providers should consider bi-directional data exchange between their EHR and the CAIR platform. CAIR also offers a Mass Vax Module, where information can be uploaded in batches. For more information on both of these options, visit https://eziz.org/covid/reporting/.

Adverse reactions will continue to be reported through the Vaccine Adverse Event Reporting System (VAERS) by Reporting an Adverse Event to VAERS.

No. Unusable doses (e.g., wasted, spoiled, and expired) must be reported but are not reported with on hand inventory. The California Department of Public Health will provide guidance on reporting wasted, spoiled, and expired doses once defined by CDC.

Providers must maintain COVID-19 vaccine administration records for a minimum of 3 years, or longer if it is required by local, state, or territorial law.

When the COVID-19 Vaccine is distributed, maintaining the cold chain is the critical first step in vaccine inventory management. Vaccine deliveries should only be scheduled at times when staff will be present because vaccines must never be left unattended. To support efficient distribution of the COVID-19 Vaccine, full day receiving hours should be available. When that is not possible, locations receiving vaccine and ancillary supply shipments must be available during a four-hour window on a weekday other than Monday. All COVID-19 vaccine and ancillary kit deliveries will require a signature. For detailed guidance, please refer to the CDC’s Vaccine Storage and Handling Toolkit. For storage and handling for current COVID-19 vaccines, also refer to Pfizer-Biontech and Moderna guidance.

You must submit a signed CDC Redistribution Agreement and a Redistribution Vaccine Management Plan to the CA Department of Public Health and receive a notice of approval prior to redistributing vaccines. This is a one-time application to routinely redistribute vaccines and you may only redistribute to other fully enrolled COVID-19 vaccination providers. Please see the Guide to Redistribution, Repositioning, or Transfer for examples of redistribution events.

Once everything is submitted, it is currently taking approximately three days to review and approve. Notification of approval will be sent via email. Redistribution of the COVID-19 Vaccine must not begin until approved.

You do not need additional approval prior to each redistribution event. Report all vaccine redistribution or transfer events to the CA Department of Public Health within 24 hours of the event using the Report Vaccine Redistribution or Transfer e-form. It is the responsibility of the sending site to report redistribution events. Additional redistribution information can be found here.

For detailed guidance of storage and handling for the COVID-19 Vaccines currently available, please refer to the CDC’s Vaccine Storage and Handling Toolkit and to Pfizer-Biontech and Moderna guides.

Storage unit temperatures must be checked and recorded twice daily to help prevent the loss of vaccines and the potential need for revaccination of patients. Any out-of-range temperatures must be documented and immediately reported. First complete the Report Temperature Excursion Worksheet to gather the information the vaccine manufacturer will need to determine whether doses may be administered. Then contact the manufacturer and report the excursion and stability determination to the COVID Call Center using the Report Temperature Excursion e-form. See Reporting Temperature Excursions for additional guidance.

Please return the Pfizer thermal shipper and temperature monitoring device within 30 days of delivery. Return instructions are providing in the Shipping & Handling Guidelines brochure, which ships with vaccines. For Moderna vaccine, follow the McKesson Vaccine Shipper Return Instructions.

Pfizer Vaccine:

• After storage for up to 30 days in the Pfizer thermal shipper, vaccination centers can transfer the vials to 2-8°C storage conditions (refrigerator temp.) for an additional five days, for a total of up to 35 days. Once thawed and stored under 2-8°C conditions, the vials cannot be re-frozen or stored under frozen conditions.
• Once you have punctured the vial: All the doses need to be administered within 6 hours, or they must be discarded.

 Moderna Vaccine:

• Vials may be stored in the refrigerator between 2°C and 8°C (36°F and 46°F) for up to 30 days before vials are punctured. After 30 days, remove any remaining vials from the refrigerator and discard following manufacturer and jurisdiction guidance on proper disposal. Thawed vaccine cannot be refrozen.
• After the first dose has been withdrawn, the vial should be held between 2° to 25°C (36° to 77°F). Discard vial after 6 hours. Do not refreeze.

DHCS is also seeking federal approval to cover the cost of the vaccine administration for Medi-Cal beneficiaries who are in restricted scope coverage, the COVID-19 Uninsured population and enrollees of the Family PACT program. Health centers will be reimbursed at Medicare rates similar to when they administer COVID-19 vaccine for other Medi-Cal beneficiaries.

Health center employees may receive COVID-19 vaccine, and the associated cost should be reimbursed by the employee’s health plan. Please contact the appropriate health plan for additional information.

Per DMHC guidance, California law requires health plans to reimburse their contracted providers for adult vaccines “on a fee-for-service basis at the negotiated contract rate or through an alternate funding mechanism mutually agreed to by” the plan and provider.

Regarding non-contracted providers, federal law requires health plans to reimburse providers at a “reasonable” rate for the cost of administering qualifying COVID-19 vaccines. Example of “reasonable” reimbursement for non-contracted providers would be the Medicare reimbursement rate for administration of COVID-19 vaccines.

During the federally declared COVID-19 public health emergency, health plans must cover the costs of administering COVID-19 vaccines to health plan enrollees regardless of whether the vaccines are administered by in-network or out-of-network providers. Additionally, health plans must cover the administration of qualifying COVID-19 vaccines with no cost-sharing, regardless of whether the enrollee receives the vaccine from an in-network or out-of-network provider.

COVID-19 vaccines and their administration will be paid the same way influenza and pneumococcal vaccines and their administration are paid in RHCs and FQHCs, which are paid at 100 percent of reasonable cost through the cost report. For Calendar Years 2020 and 2021, Medicare payment for the COVID-19 vaccine and its administration for beneficiaries enrolled in Medicare Advantage plans will be made through the traditional Medicare program. See CMS Guidance for more information.

On December 18, 2020, DHCS submitted State Plan Amendment 20-0040 seeking federal approval to reimburse FQHCs, RHCs, and Tribal clinics for COVID-19 vaccine administration outside of the PPS or AIR rate and exclude these FFS payments from annual reconciliation.  The SPA is currently pending CMS approval. 

All Facilities Letter 20-46.2 outlines the process for health care facilities to request staffing resources from the state. Health centers must report these as unusual occurrences to the CDPH Licensing and Certification District Office. CDPH, in collaboration with the local public health department, will assess the situation and determine whether the facility can continue to operate safely.

At the same time, the local public health department will contact the Medical Health Operational Area Coordinator to begin the process of locating resources within the local area, region, or state. State resources include the California Emergency Medical Services Authority’s California Medical Assistance Teams, the California Health Corps, or other staffing contracts.

AFL 20-30 waives program flexibility request requirement allowing health centers to set up outdoor screening/testing kiosk, tent, etc. This AFL applies to COVID-19 vaccination and is valid until March 1, 2021.

If a health center wants to maintain FTCA coverage for COVID-19 vaccination activity, then it needs to take steps to ensure the activity is in scope. HRSA issued a particularized determination earlier this year extending FTCA coverage to COVID-19 activities for non-FQHC patients. According to the guidance from HRSA and FTCA, FTCA will continue to cover provision of in scope services to non-FQHC patients as they have been doing through the emergency. Here are some resources for health centers in this space:

• Considerations for Health Center Scope of Project and the Public Health Emergency: It’s important to remember that FTCA coverage applies only to what is included in the health center’s scope of project. For the emergency, HRSA has expanded the scope to non-FQHC patients in certain scenarios, and this includes the FTCA coverage. However, health centers still need to make sure that their scope of project includes or will include any new locations where services are being provided. This webpage is essentially a checklist a CHC can use to make sure that their activities do meet the current guidelines in order to qualify to be in scope and covered by FTCA.
• Determination of Coverage for COVID-19-Related Activities by Health Center Providers: This is the particularized determination HRSA issued earlier in the year that extends FTCA coverage for all deemed health centers. The language here is clear that treatment to individuals who are not established patients is covered. Health centers should maintain “a record of each encounter that identifies the patient, the service(s) provided, the location where services were administered, the name of the provider(s) administering the services, and the date and time the services were administered.”

Uniform Data System: A vaccine alone does not meet the criteria of a UDS countable visit. Therefore, if during the reporting year an individual receives only a vaccination at your health center, this patient would not be considered to have had a UDS countable visit and therefore would not be reported anywhere on the UDS report. 

Health centers will report the count of patients who received the vaccine on the UDS Other Data elements Form, Appendix E. (Source: HRSA UDS Novel COVID-19 Reporting). Patients reported on this line are health center patients (i.e., patients with at least one UDS visit reported on Table 5) who have evidence of having received a FDA approved COVID-19 vaccine in their record within the reporting year (i.e., 2020). The vaccine does not need to be administered during a UDS countable visit, but needs to be provided to a patient who had one or more reportable visits during the year.

Medi-Cal: Existing QI/P4P arrangement between health centers and Medi-Cal Managed Care Plans should not be affected by increased numbers of vaccine-only visits for community members. Additionally, Medi-Cal quality metrics mostly focus on assigned Medi-Cal beneficiaries. If you have concerns or anticipate issues, please reach out directly to your contracted Medi-Cal plans.

On December 16, 2020, the EEOC updated their COVID-19 guidance to include information relating to COVID-19 vaccinations in the workplace and considerations tied to mandating vaccinations. Health centers may encourage or possibly require COVID-19 vaccinations, but policies must comply with the Americans with Disabilities Act (ADA), Title VII of the Civil Rights Act of 1964 (Title VII) and other workplace laws, according to the EEOC.

The California Department of Public Health maintains a list of licensees that are authorized to administer vaccines in California. It is frequently being updated as the Department of Consumer Affairs releases waivers due to the public health emergency. We encourage health centers to check out these two locations to review the latest information.

Health centers are leveraging a variety of strategies to expand the number of individuals available to support the COVID-19 vaccine efforts:

• Identifying and working with licensed volunteers who are eligible to administer the vaccine
• Collaborating with academic institutions to have eligible students administer the vaccine
• Hiring more California licensed providers that are eligible to administer the vaccine
• Contracting with healthcare temp/medical staffing agencies to fill temporary positions for eligible licensees
• Engaging with Local Health Departments to request Emergency Medical Personnel; California Medical Assistance Teams (CAL-MAT), Disaster Healthcare Volunteers, Medical Reserve Corps
• Partnering with paramedics and emergency medical technicians
• Submitting “Requests for Temporary Recognition of Out-of-State Medical Personnel During a State of Emergency” to the Emergency Medical Services Authority (EMSA)

All Facilities Letter 20-46.2 outlines the process for health care facilities to request staffing resources from the state. Health centers must report these as unusual occurrences to the CDPH Licensing and Certification District Office. CDPH, in collaboration with the local public health department, will assess the situation and determine whether the facility can continue to operate safely.

At the same time, the local public health department will contact the Medical Health Operational Area Coordinator to begin the process of locating resources within the local area, region, or state. State resources include the California Emergency Medical Services Authority’s California Medical Assistance Teams, the California Health Corps, or other staffing contracts.

Health centers can take advantage of two new volunteer programs that are supporting the COVID-19 vaccination efforts. MyTurnVolunteer is operated through CA Volunteers, and VaxForce is operated through HealthImpact. Both programs allow health centers to recruit clinical and non-clinical volunteers for support with outreach, education, and vaccination administration.

Check out these webinars from our OnDemand Library!
MyTurnVolunteer
VaxForce

• Late January - The U.S. Health and Human Services Secretary Azar declared COVID-19 a public health emergency, shortly after the World Health Organization issued similar declaration.

• March 6, 2020 - President Trump signed into law HR 6074 - Coronavirus Preparedness and Response Supplemental Appropriations Act.  HR 6074 included $8.3 billion in funding to help local and state government with preparedness, mitigation, and response efforts. HR 6074 also included $100 million dedicated to health centers to combat COVID-19 and $500 million to expand the availability of telehealth services to Medicare patients.

• March 13, 2020 - President declared a national emergency, unlocking CMS authority to waive Medicare and Medicaid requirements.

• March 14, 2020 - The House passed a second COVID-19 related bill, HR 6201 - the Families First Coronavirus Response Act. The bill, once passed by the Senate and signed into law, will address food insecurity problems, create emergency paid sick leave for employees recovering from COVID-19 or caring for ill relatives, provide additional funds to states to pay for unemployment benefits related to COVID-19, and mandate testing with no cost to the consumer whether they are commercially insured, covered by Medicare, or covered by Medi-Cal, allows states to modify state Medicaid plans to include COVID-19 testing for uninsured and temporarily increases the Federal Medical Assistance Percentage (FMAP) for the matching funds states receives to support certain medical and social service programs, including Medi-Cal.  At time of writing, this bill is awaiting senate action.

• March 27, 2020 – President Trump signed the Coronavirus Aid, Relief, and Economic Security (CARES) Act into law. In addition to key funding provisions within the Act, there are impacts to human resources, workforce, and care delivery. To see NACHC’s summary of the CAREs Act, please click here.

• July 27, 2020 - Senate Republicans rolled out a fourth COVID-19 stimulus package totaling at just under $1 trillion. The package is titled the HEALS (Health, Economic Assistance, Liability Protections & Schools) Act and was introduced through a series of individual bills. This package was released in response to the HEROES Act, the COVID-19 stimulus package passed by the House of Representatives this past May. To read NACHCs summary of the HEROES Act, click here.

  There are several differences between the two packages, which has led to ongoing negotiations over several weeks, with few signs of an agreement coming together soon. Due to the lack of agreement, the Administration recently issued several Executive Orders and other directives to contrast with Congress’ inaction. 

• March 4, 2020 - Governor Newsom declared a state of emergency in California, escalating state responses to the COVID-19 pandemic.

• Shortly after, Gov. Newsom began issuing executive orders (EO) to support the health and wellbeing of all Californians. To see a full list of executive orders click here.

• March 16, 2020 - The state legislature, before announcing a recess through April 13, 2020, waived constitutional rules to allow the legislature to pass emergency legislation and budget appropriations. SB 89 amends the budget act of 2019-20 to appropriate $500 million from the General Fund to be used for any purpose related to the Governor’s March 4, 2020 declaration of emergency and authorizes up to $1 billion in  future COVID-19 expenditures. SB 117 specifically provides for the funding of schools and waiving of education-related timelines.

• In mid-August - CaliforniaHealth+ Advocates launched a Virtual Care Advocacy Campaign. COVID-19 pandemic has shown that, now more than ever, California’s Community Health Centers (CHCs) require innovative tools to help reach special populations, better protect health care workers and patients all while guaranteeing timely access to care. For CHC to remain viable, they must be able to continue to provide virtual care to your patients. Therefore, as this legislative session comes to an end, we must urge lawmakers to take urgent action and adopt trailer bill language in this session to allow telehealth flexibilities and telephonic allowances to be extended indefinitely.

Health Center COVID-19 Information Collection
Beginning April 6th, HRSA will open the health center COVID-19 survey ONCE a week on Friday afternoons. HRSA is requiring health centers fill out this survey to help track the number of patients that have undergone testing at each health center along with other critical information. Please visit the Information Collection section of the HRSA FAQs for details.

Each health center will receive an electronic, easy to use survey (reducing the need for telephonic, email, or other methods of gathering critical COVID-19 related information) once a week via email from BPHCanswers@hrsa.gov.

HRSA will use the information collected to assess health centers' needs throughout the COVID-19 response, to share critical information related to testing, cases, and impacts at health centers, and to better understand training and technical assistance, funding, and other resource needs.

CPCA has put together Frequently Asked Questions (FAQs) specific to COVID-19 and FTCA that can be accessed here . For more information, please contact Emily Shipman, Assistant Director of Health Center Operations, eshipman@cpca.org.

To ensure that Emergency Operations Plans are in place, discussing resource needs for the health center, and continuing to meet monthly per HRSA requirements.  Click here for more detailed information on each area.

Posted: 3/25/2020

The best way to get supplies in California is to request them through the Medical and Health Operational Area Coordinator (MHOAC) Program.

A list of county MHOAC contacts is here. It is important to continue submitting requests through this system to ensure health center resource needs are relayed at the State and federal level. Please send any challenges experienced to Amanda Carbajal at acarbajal@cpca.org.

CDC PPE Burn Rate Calculator: This is a useful tool to help better understand how much PPE your health center is using and to help assess how much PPE to request.

You must report COVID-positive patients to your local public health officer. Some local public health officers have a form they want the hospital to complete, while others take information over the phone and complete the paperwork themselves. Check with your local public health department to learn their process. You do not need to report suspected cases or persons under investigation (PUIs), unless your local public health officer has directed you to do so. However, if you have an unusual PUI case and believe it should be brought to the attention of your local public health officer, then do so.

NACHC has brought together resources for health centers to better understand how the Strategic National Stockpile works and how understanding the supply chain to request resources from the federal government is essential. Additionally, NACHC sent a letter to the FEMA Administrator informing him of the role health centers are playing in their local responses, along with developed a template for PCAs to share with their own state emergency managers and Governor emphasizing these points. Finally, during this time staying vigilant and aware of potential fraud from vendors selling emergency related supplies and resource is an essential part of daily operations.

• Understanding the Strategic National Stockpile (SNS)
• Understanding Supply Chain Coordination
• Fraud Schemes Guidance Alert

Yes, the CDC has issued detailed strategies for optimizing supplies of eye protection, isolation gowns, face masks, and N95 respirators. In addition, the Food and Drug Administration (FDA) has issued emergency use authorization for various mask and respirator decontamination systems. In early June, the FDA reissued emergency use authorizations that revise policy on the types of N95 respirators that can be decontaminated for reuse. Per the CDC, use of respirators that have been decontaminated should be reserved as a crisis strategy.

There are two different types of tests: diagnostic tests and antibody tests. Diagnostic tests are classified as either a molecular test or an antigen test. The molecular (RT-PCR) test detects the virus’ genetic material, and the antigen test detects specific proteins on the surface of the virus.  

Antibody tests detect antibodies that are made by the immune system in response to a threat, such as a specific virus. Antibody tests are called serology tests and should not be used to diagnose an active coronavirus infection. For more information, visit www.fda.gov/consumers/consumer-updates/coronavirus-testing-basics.

The California COVID-19 Testing Task Force has developed a PCR Test Analysis spreadsheet explaining the individual tests.

The California Department of Public Health (CDPH) released updated testing guidance in July that includes four tiers of testing priority, with the first tier being hospitalized individuals with signs or symptoms of COVID-19; people being tested as part of the investigation and management of outbreaks, including contact tracing; and close contacts of confirmed cases.

Contact your local health department for the information, and check the updated information on the state testing task force website.

Uniform Data System:  A vaccine alone does not meet the criteria of a UDS countable visit. Therefore, if during the reporting year an individual receives only a vaccination at your health center, this patient would not be considered to have had a UDS countable visit and therefore would not be reported anywhere on the UDS report. 

Health centers will report the count of patients who received the vaccine on the UDS Other Data elements Form, Appendix E. (Source: HRSA UDS Novel COVID-19 Reporting). Patients reported on this line are health center patients (i.e., patients with at least one UDS visit reported on Table 5) who have evidence of having received a FDA approved COVID-19 vaccine in their record within the reporting year (i.e., 2020). The vaccine does not need to be administered during a UDS countable visit, but needs to be provided to a patient who had one or more reportable visits during the year.

Medi-Cal: Existing QI/P4P arrangement between health centers and Medi-Cal Managed Care Plans should not be affected by increased numbers of vaccine-only visits for community members. Additionally, Medi-Cal quality metrics mostly focus on assigned Medi-Cal beneficiaries. If you have concerns or anticipate issues, please reach out directly to your contracted Medi-Cal plans.

No. Per AFL 20-30, Primary Care Clinics do not need to submit individual program flexibility requests for the regulations specified in the AFL. The waiver includes permission for drive-thru COVID-19 screening/testing. This waiver is valid until March 1, 2021, and may be extended based on any updated Executive Order.

Yes. Per AFL 20-30, an intermittent clinic operated be a PCC may extend operating hours beyond 40 hours per week during the current declared state of emergency. This waiver is valid until March 1, 2021, and may be extended based on any updated Executive Orders.

Yes. Per AFL 20-30, PCCs with pending applications for clinic licensure may begin providing care prior to approval by CDPH during the current declared state of emergency.

Please Note: Effective dates for Medi-Cal certification may not currently align with licensing flexibility given by CDPH. CPCA staff continue work to clarify Medi-Cal enrollment/billing requirements set by DHCS for new clinic sites during the state of emergency. This waiver is valid until March 1, 2021, and may be extended based on any updated Executive Orders.

A PCC shall not be subject to the 60-day prior notice requirement when changing a service, remodeling, modifying, or adding an additional physical plant during the current declared state of emergency. This waiver is valid until March 1, 2021, and may be extended based on any updated Executive Orders.

CPCA recommends health center dental programs to follow the California Department of Public Health’s (CDPH) Guidance for Resuming Deferred and Preventive Dental Care. This guidance is based on what is currently known about the transmission and severity of coronavirus disease 2019 (COVID-19) and the implications for dental practice. CDPH will update this guidance as additional information becomes available.

The face covering order requires Californians to wear face coverings when they are obtaining services from the health care sector in settings including, but not limited to, a hospital, health center, laboratory, physician or dental office, veterinary clinic, or blood bank, unless directed otherwise by an employee or healthcare provider.

The state has identified the following exceptions:

• When directed otherwise by a health care provider or other employee of the hospital, pharmacy, clinic, lab, physician or dental office, or blood bank
• Children age two or younger. These very young children must not wear a face covering because of suffocation risk.
• Anyone with a medical or mental health condition, or a disability that prevents wearing a face covering. This includes those with a medical condition for whom wearing a face covering could obstruct breathing or who are unconscious, incapacitated, or otherwise unable to remove a face covering without assistance.
• Persons who are hearing impaired, or communicating with a person who is hearing impaired, where the ability to see the mouth is essential for communication.
• Anyone receiving a service involving the nose or face for which temporary removal of the face covering is necessary to perform the service.

AB 1494 removes barriers to Medi-Cal reimbursement for FQHCs and RHCs during a state of emergency for telehealth and telephonic services and services provided outside the four walls of the health center.  Effective March 1, 2020, the telehealth flexibilities are implemented under approved SPA 20-0024. 

Additionally, the CARES Act authorizes FQHCs and RHCs to serve as distant telehealth providers for Medicare for the duration of the COVID-19 public health emergency.  FQHCs and RHCs can provide and bill for distant telehealth services starting on January 27, 2020 through the end of the public health emergency. Payment to RHCs and FQHCs for distant site telehealth services is set at $92.03. Since the telehealth distant site services are reimbursed at a FFS rate, the Medicare Advantage wrap-around payment does not apply to these services. See the CMS guidance for additional details. 

Eligible FQHCs can serve as telehealth originating site providers beyond the COVID-19 PHE; however, FQHCs would not be authorized to serve as telehealth distant site providers in the absence of the current telehealth flexibilities for Medicare. One of CPCA’s top policy priorities is maintaining current telehealth flexibilities for both Medicare and Medi-Cal, including payment for telephone visits, beyond the federal and state declarations of emergency.  As such, CPCA is working with statewide and national partners to advocate for maintaining current telehealth flexibilities.  

Covered health care providers may use popular applications that allow for video chats, including Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, Zoom, or Skype, to provide telehealth without risk that OCR might seek to impose a penalty for noncompliance with the HIPAA Rules related to the good faith provision of telehealth during the COVID-19 nationwide public health emergency. See the HHS announcement for details.

FQHCs can continue to provide and bill for telehealth services according to the Medi-Cal Telehealth Policy for FQHCs, RHCs, and IHS-MOAs.  Without the current telehealth flexibilities, there would be more restrictions on telehealth services and reimbursement. Telephone services would not be billable without the current telehealth flexibilities.

Executive Order N-43-20 temporarily waived the patient consent requirements for telehealth services. However, DHCS advises providers to follow the current best practice, which is to obtain and document verbal or written patient consent to the best of the provider’s ability.

FQHCs and RHCs may not bill Medi-Cal for mental health and medical visits on the same day. FQHC, RHC, or Tribal 638 covered services provided via a virtual/telephonic visit are subject to the same program restrictions, limitations, and coverage that exist when the service is provided face-to-face.

FQHCs and RHCs can bill Medi-Cal directly for the wrap/crossover/capitated Medicare Advantage claim for telephone or telehealth visits for dual eligible patients. When billing for telehealth services for dual eligible patients, FQHCs and RHCs should bill Medicare for distant site telehealth services according to the CMS guidance and bill Medi-Cal for the wrap, cross-over, or capitated Medicare Advantage claim using the same billing process as an in-person visit.

When billing for telephonic visits for dual eligible patients, FQHCs and RHCs should follow the billing instructions listed in Section III of the DHCS guidance. If the visit meets the documentation criteria, the visit is PPS eligible and should be billed using the applicable revenue code and HCPCS code on the payable line as well as the corresponding CPT code [99201-99205 (new patient)/ 99211-99215 (established patient)] on the informational line. Additional CPT codes corresponding to services provided during the visit can be added as informational line items. If the telephone visit does not meet documentation criteria, it should be billed using HCPCS code G0071 (do not include CPT codes) for FFS reimbursement in the amount of $13.69. An EOMB is not required for telephonic visits.

NACHC developed a COVID-19 Community Health Center Finance Toolkit in critical areas in order for community health center leaders to guide their teams through difficult times and prepare them to come out stronger on the other side. California’s state treasurer office has developed a running list of federal, state, local, and private funding opportunities. A combination of loans and grants are available to support organizations during this crisis- find the full list here. California also launched a Small Business Disaster Relief Loan Guarantee Program for small businesses with up to 750 employees.

The Paycheck Protection Program (PPP) at the U.S. Small Business Administration can be used for payroll support, insurance premiums, and mortgage, rent and utility payments. While the initial $349 billion from the CARES Act was utilized within the first two weeks of the program, President Trump signed legislation on April 24, 2020 providing an additional $310 billion for this program. Community health centers eligible through the employee-based (500 employees or less) or revenue-based size standards (max net worth of $15M and average net income of $5M) can submit an application through SBA lenders. Additional information can be found on the PPP FAQs. CPCA also created a webcast alongside Melissa Schoen and MaryKate Scott to share how community health centers can calculate the Paycheck Protection Program loan, use the loan fund, qualify for loan forgiveness, and submit an application. BKD also released a set of FAQs based on the SBA’s second round of Paycheck Protection Program clarifications.

UPDATE: The U.S. Internal Revenue Service (IRS) released on April 30, 2020 Notice 2020-32, which “clarifies that no deduction is allowed under the Internal Revenue Code (Code) for an expense that is otherwise deductible if the payment of the expense results in forgiveness of a covered loan pursuant to section 1106(b) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).” It is our understanding that this means no deductions will be allowed for expenses that were forgiven under the PPP loan.

UPDATE: The Paycheck Protection Program Flexibility Act was enacted on June 5, 2020 and made changes to the PPP. In particular, it increase the amount of time borrowers have to spend loan funds (24 weeks vs. 8 weeks); decreased the portion of funds that need to be spent on payroll (60% vs. 75%); extended the deadline for returning to pre-pandemic staffing and payroll levels (December 31st instead of June 30th); etc. 

UPDATE: On Tuesday, March 30, 2021, President Joe Biden signed the PPP Extension Act of 2021 into law, extending the Paycheck Protection Program an additional two months to May 31, 2021, and then providing an additional 30-day period for the SBA to process applications that are still pending. Learn more here.

In response to President Trump's declaration of a national emergency and emergency declarations by all states, many health care entities have taken unprecedented steps regarding licensure portability and the deployment of appropriate health workforce resources. In this time of national emergency, the NPDB is waiving its entity query fees to support health systems. To support these entities during this national emergency, the NPDB is extended their waiving query fees (both one-time query and continuous query). The waiver is retroactive from March 1, 2020, through September 30.  The NPDB will issue query credits to reimburse entities that conducted queries (one-time and continuous) between March 1 and the implementation of the fee waiver. For updated information about the waiver, visit the Coronavirus (COVID-19) Information page on the NPDB website.

CPCA recently developed an H-1B Visa FAQ   that outlines commonly asked questions and aims to strengthen your understanding of H-1B employer requirements during the COVID-19 pandemic. In addition to reviewing the FAQ, you are encouraged to consult with your legal counsel to ensure H-1B visa compliance with federal regulations.

Health centers interested in HR policies and procedures are encouraged to check out CPCA’s COVID-19 Community Forum library in Connected Communities or raise the request through the discussion board.

Registration is done at the organization level.  If the clinic site is part of a FQHC organization, the parent organization would complete part A and each individual clinic site would complete part B.  A standalone clinic would complete part A and part B.      

Governor signed Executive Order N-39-20, which allowed the Department of Consumer Affairs (DCA) to issue waivers related to relaxed supervision caps, expedited licensure reinstatement, extended licensing deadlines, and other workforce expansion strategies. To date, DCA has issued several waivers. Click here to read more.

The Work Sharing Program helps employers and employees avoid some of the burdens that accompany a layoff situation. Participating organizations retain their workers by reducing their hours and wages no more than 60 percent and partially offset the wage loss with UI benefits. This helps organizations avoid the cost of recruiting, hiring, and training new workers and helps workers keep their jobs and receive some financial support with UI benefits. Organizations and their workers can also be prepared to quickly adjust when business improves. For additional information on the Work Sharing Program, contact the EDD Special Claims Office at 916-464-3343.

If your employer reduced your hours or shut down operations due to COVID-19, you are encouraged to file an Unemployment Insurance (UI) claim. UI provides partial wage replacement benefit payments to workers who lose their job or have their hours reduced. Workers who are temporarily unemployed due to COVID-19 and expected to return to work with their employer within a few weeks are not required to actively seek work each week. However, they must remain able, available, and ready to work during their unemployment for each week of benefits claimed and meet all other eligibility criteria.

Additional information is available on the California Employment Development Department (EDD).

Individuals who are unable to work due to having or being exposed to COVID-19 (certified by a medical professional) can file a Disability Insurance (DI) claim with the California Employee Development Department. For fastest processing of your claim, submit your claim online and have the supporting medical documentation submitted online immediately after.

Health centers experiencing a hardship as a result of COVID-19 may request up to a 60-day extension of time from the California Employment Development Department (EDD) to file their state payroll reports and/or deposit state payroll taxes without penalty or interest. A written request for extension must be received within 60 days from the original delinquent date of the payment or return. For questions, health centers may call the EDD Taxpayer Assistance Center (1-888-745-3886). Click here for more information.

Several federal, state and local government agencies have provided resources to help employers and employees navigate workplace issues related to COVID-19. CPCA encourages health centers review the frequently updated information posted on the sites below.

FEDERAL RESOURCES

Centers for Disease Control and Prevention
Workplace & Businesses
Criteria for Return to Work for Healthcare Personnel with SARS-CoV-2 Infection

U.S. Department of Labor Occupational Safety and Health Administration 
OSHA Requirements, Guidance, etc.

U.S. Department of Labor Wage & Hour Division
COVID-19 & Fair Labor Standards Act FAQ

The Equal Employment Opportunity Commission (EEOC)
COVID-19 & Antidiscrimination FAQs

Health Resources & Services Administration COVID-19 Webpage
COVID-19 & FAQs for Health Centers

US Department of Health & Human Services
COVID-19 Workforce Virtual Toolkit: Resources for Healthcare Decision Makers Respond to COVID-19 
Workforce Concerns

STATE RESOURCES

CA Department of Public Health
COVID-19 Employer Playbook for a Safe Reopening

CA Department of Industrial Relations
CAL/OSHA's Aerosol Transmissible Diseases Standard
CalOSHA & Statewide Industry Guidance on COVID-19

CA Employment Development Department (EDD)
FAQ On Disability Or Paid Family Leave Benefits, Unemployment Insurance, Employer Information 

CA Labor & Workforce Development Agency
Guidance for Workers and Employers

CA Division of Labor Standards Enforcement (DLSE)
FAQs On Laws Enforced By The California Labor Commissioner's Office

CA Department of Education
Emergency Childcare Services

Yes, eligible patients can apply for Medi-Cal benefits and will have benefits be retroactive to the signup date; or apply for coverage through Covered California. Covered California extended the Special Open Enrollment period until August 31, 2020. Additionally,DHCS has suspended Medi-Cal annual eligibility determination until the end of the Public Health Emergency. 

Family PACT providers may enroll and recertify clients through telehealth or other virtual/telephonic communication modalities, throughout the course of the COVID-19 emergency. Click the link to read the full guidance for Family PACT providers, including instructions for telephonic client enrollment and re-certification.

Patients with any insurance coverage will receive free COVID-19 screening and testing.

The Department of Health Care Services created a new Presumptive Eligibility program (PE COVID-19) that will allow individuals to seek the necessary diagnostic testing, related services including clinic or emergency room visit, at no cost to the individual.

The aid code will be available to individuals with no insurance or those with private insurance that does not cover diagnostic testing and all testing-related services associated with COVID-19. The aid code will be available to California residents, without regard to immigration status, income, or resources. A patient can access free services through PE COVID-19 by visiting a PE Qualified Provider, who will submit an application and determine eligibility within 24 hours. The PE COVID-19 enrollment period begins on the date of application and ends on the last day of the following month in which the individual was determined eligible for PE.

The PE COVID-19 Program became effective April 25, 2020.Instructions on how to enroll patients into this program may be found here.