November NHIC incentive payments were sent to providers beginning the week of January 25 and December payments began arriving on February 12. HHS did not issue a press statement or provide any advanced information about these distributions.

Below is LeadingAge’s analysis of the published information.

For November performance (NHSN data for Nov. 2 – Nov. 29, 2020):

• 7,564 nursing homes received infection control incentive payments
• HHS distributed a total of roughly $556 million for November performance
• The smallest incentive payment was $167.25; the largest payment received was $619,211 with an average payment of about $73,519
• 90% of qualifying nursing homes had 0 cases of COVID-19 during the performance period but one nursing home that had 6 infections also was eligible because they performed better than their community. This is a departure from the September and October incentive, which saw no nursing home receiving an incentive if they had more than 3 COVID-19 infections acquired in their home.

For December performance (NHSN data for November 30 – December 27,2020):

• 6,227 nursing homes received infection control incentives based upon their performance
• HHS distributed a total of roughly $512 million for December performance
• The smallest incentive payment was $112.26 and the largest was $605,592 with an average payment of $82,290
• According to the data, it proved tougher to keep COVID-19 at bay with 83% of nursing homes qualifying with 0 infections, 13.7% had at least 1 infection; and the remainder had 2 or more with 3 nursing homes qualifying with with as many as 6 infections. 

Just a reminder, the NHIC incentives are based upon nursing home’s ability to control the number of COVID-19 infections acquired within the nursing home in comparison to the rate of infection per 1000 in their surrounding community, and the mortality rate during the performance period. For those trying to make sense of why they may not have received a payment or how the payment amounts are determined, you can find an explanation of the HHS methodology used to determine eligibility for these payments here.

It should also be noted that the December payment is the last NHIC incentive payment nursing homes will receive under the program. Originally, HHS (under the Trump Administration) had suggested it would also issue an incentive payment based upon aggregate performance over the four months of the program but later changed this position to have the program end with the December performance. The result was that the remaining nearly $1.1 billion was divided among the last two monthly payments. $856M was distributed for nursing home’s September and October performance.

Providers receiving these payments should remember that these funds can only be used for infection control expenses outlined in the terms and conditions for NHIC payments. In addition, due to new law passed in December, if a nursing home is a subsidiary of a parent organization, the law now permits the parent organization to reallocate this targeted distribution (i.e., the NHIC incentive payment) to another eligible health care provider within the organization. However, the nursing home who originally received the payment will still be responsible for the required reporting on the payment.