Coronavirus Update #128
MDH Testing Memo, MDH Recorded Webinar on Reopening, Enhanced Enforcement for Infection Control Deficiencies, CMS Webinar on PPE Strategies
MDH Memo Regarding Testing

Today the Maryland Department of Health released this memo regarding testing.

This memo provides information regarding the second round of nursing home testing. Based on CDC guidance, the Maryland Department of Health (MDH) Guidance for Relaxation of Restrictions Implemented During the COVID-19 Pandemic - Nursing Homes of June 18 2020, and the Secretary’s Amended Directive and Order Regarding Nursing Home Matters of June 19, 2020, all nursing homes in Maryland are required to continue testing for COVID-19 on a weekly basis. 


  • Nursing homes without an active COVID-19 outbreak must test all staff.

  • Individuals who have tested positive within eight weeks do not need to be retested if:
  1. They have completed isolation based on a time, test, or symptom-based strategy per CDC guidelines, and
  2. Have remained asymptomatic for COVID-19 symptoms.

In this second round of testing, MDH is coordinating free testing for all nursing homes through one of two laboratories; either the University of Maryland Medical School (UMB) Lab or CIAN Diagnostics Lab.

Nursing homes will be contacted by one of these two labs to offer testing and collect the information needed to order the tests. To support the ongoing testing efforts, all nursing homes should maintain rosters of their residents and staff and use these rosters in ordering COVID-19 tests from the labs. The labs will communicate any specifics needed for ordering directly to the nursing homes.

If you have lab related issues, you should call the lab. If you have public health questions or concerns, you should call your local health department.
MDH Webinar on Reopening Guidance

Earlier this week, the Maryland Department of Health held a webinar for providers regarding relaxing restrictions in long-term care. This webinar was recorded in case you were unable to join or would like to review topics discussed. This webinar covered:



  • Phases of reopening

  • Restrictions that will not be relaxed

  • Reopening criteria

  • Testing capacity and issues

  • Q&A
Enhanced Enforcement for Infection Control Deficiencies


Infection Control requirements are nothing new, but the Centers for Medicare and Medicaid Services (CMS) is ramping up efforts to identify and assist providers who may be performing poorly in infection control practices. Providers struggling to comply with requirements could face corrective action and Civil Monetary Penalties (CMP) as outlined below. See the full memo here: QSO-20-31-All

Due to the heightened threat to resident health and safety for even low-level, isolated infection control citations (such as proper hand-washing and use of personal protective equipment (PPE), CMS is expanding enforcement to improve accountability and sustained compliance with these crucial practices.

Substantial non-compliance (D or above) with any deficiency associated with Infection Control (IC) requirements will lead to the following enforcement remedies:

  • Non-compliance for an IC deficiency when none have been cited in the last year (or on the last standard survey):
  • Cited current non-compliance (Level D & E) – Directed POC
  • Cited current non-compliance (Level F) – Directed POC, Discretionary Denial of Payment for New Admissions with 45-days to demonstrate compliance with IC deficiencies.

  • Non-compliance for IC Deficiencies cited once in the last year (or last standard survey):
  • Cited current non-compliance (Level D & E) -Directed POC, Discretionary Denial of Payment for New Admissions with 45-days to demonstrate compliance with IC deficiencies, Per Instance Civil Monetary Penalty (CMP) up to $5000 (at State/CMS discretion)
  • Cited current non-compliance (Level F) -Directed POC, Discretionary Denial of Payment for New Admissions with 45-days to demonstrate compliance with IC deficiencies, $10,000 Per Instance CMP

  • Non-compliance that has been cited for Infection Control Deficiencies twice or more in the last two years (or twice since second to last standard survey)
  • Cited current non-compliance (Level D & E) – Directed POC, Discretionary Denial of Payment for New Admissions, 30-days to demonstrate compliance with IC deficiencies, $15,000 Per Instance CMP (or per day CMP may be imposed, as long as the total amount exceeds $15,000
  • Cited current non-compliance (Level F) – Directed POC, Discretionary Denial of Payment for New Admissions, 30-days to demonstrate compliance with IF deficiencies, $20,000 Per Instance CMP (or per day CMP may be imposed, as long as the total amount exceeds $20,000)

  • Nursing Homes cited for current non-compliance with IC Deficiencies at the Harm Level (Level G, H, I), regardless of past history –
  • Directed POC, Discretionary Denial of Payment for New Admissions with 30-days to demonstrate compliance with IC deficiencies. Enforcement imposed by CMS Location per current policy, but CMP imposed at highest amount option within the appropriate (non-Immediate Jeopardy) range in the CMP analytic tool

  • Nursing Homes cited for current non-compliance with Infection Control Deficiencies at the Immediate Jeopardy Level (Level J, K, L) regardless of past history –
  • In addition to the mandatory remedies of Temporary Manager or Termination, imposition of Directed Plan of Correction, Discretionary Denial of Payment for New Admissions, 15-days to demonstrate compliance with Infection Control deficiencies. Enforcement imposed by CMS Location per current policy, but CMP imposed at highest amount option within the appropriate (IJ) range in the CMP analytic tool.

If you haven’t yet had a focused infection control survey be aware that state survey agencies must complete 100% of the focused surveys by July 31st, 2020 or be subject to corrective action. In addition, state survey agencies must:

  • Perform on-site surveys (In June, 2020) of nursing homes with previous COVID-19 outbreaks, defined as:
  • Cumulative confirmed cases/bed capacity at 10% or greater; or
  • Cumulative confirmed plus suspected cases/bed capacity at 20% or greater; or
  • Ten or more deaths reported due to COVID-19.

  • Perform on-site surveys (within three to five days of identification) of any nursing home with 3 or more new COVID-19 suspected and confirmed cases in the since the last National Healthcare Safety Network (NHSN) COVID-19 report, or 1 confirmed resident case in a facility that was previously COVID-free. State Survey Agencies are encouraged to communicate with their State Healthcare Associated Infection coordinators prior to initiating these surveys.

  • Starting in FY 2021, perform annual Focused Infection Control surveys of 20 percent of nursing homes based on State discretion or additional data that identifies facility and community risks.
CMS Webinar: Personal Protective Equipment (PPE) Strategies for COVID Care

Following this call, participants will understand why using personal protective equipment (PPE) is necessary for infection prevention and will be able to describe how to properly use it. Additionally, participants will learn how to use an audit tool for tracking compliance in proper use of PPE. An auditing tool will be shared with participants. Lastly, we will share promising practices and strategies for PPE supply and proper use.
DETAILS
Date: Thursday, June 25, 2020
Time: 4:00 – 5:00 PM ET
Advance Registration Required: Register here.

Note: Once you register, you will receive an email with your individual link to join the webcast. The link you receive will only work for one user. Please forward this email to other team members if you would like them to attend so they can register.


Audience: Open to nursing home leaders, clinical and administrative staff members and others interested in nursing home infection prevention in the era of COVID-19.

Series Description: The National Nursing Home Training Series is brought to you by the Centers for Medicare & Medicaid Services (CMS) and the QIO Program, a national network of Quality Innovation Network-Quality Improvement Organizations (QIN-QIOs) serving every state and territory.

Meet the Speakers:
Jane Brock, MD, MSPH
Medical Director
Telligen
 
Sherry Longacre, MS, RN
Sr. Quality Improvement Facilitator
Telligen

Invitations are distributed weekly for each training in the series. Sign up here for updates .

Miss a training? View recordings, slides and resources on QIOProgram.org .
CMS COVID-19 Stakeholder Engagement Calls – Week of 6/22/2020

CMS hosts varied recurring stakeholder engagement sessions to share information related to the agency’s response to COVID-19. These sessions are open to members of the healthcare community and are intended to provide updates, share best practices among peers, and offer attendees an opportunity to ask questions of CMS and other subject matter experts.

Call details are below. Conference lines are limited so you are highly encouraged to join via audio webcast, either on your computer or smartphone web browser. You are welcome to share this invitation with your colleagues and professional networks. These calls are not intended for the press.

 

Weekly COVID-19 Care Site-Specific Calls

CMS hosts weekly calls for certain types of organizations to provide targeted updates on the agency’s latest COVID-19 guidance. One to two leaders in the field also share best practices with their peers. There is an opportunity to ask questions of presenters if time allows.
 
 
Nurses (2nd and 4th Thursdays at 3:00 PM Eastern)
Thursday, June 25th at 3:00 – 3:30 PM Eastern
Toll Free Attendee Dial-In: 833-614-0820; 
Access Passcode: 9496814
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from our federal and state partners.
Thank you.

We cannot thank you enough for the dedication and diligence in doing all that you can for the residents in your communities. HFAM continues to monitor the COVID-19 pandemic with our state and national partners and will do all we can to support you during this time.