Update from the Health Facilities
Association of Maryland (HFAM)
Friends,

Thank you for all that you are doing for Maryland and your constituents. We cannot thank you enough for your leadership and dedication. We truly appreciate your hard work and look forward to our continued work together to protect quality care for Marylanders in need. I am writing today with an update on visitation, observation, testing, and vaccine distribution in the long-term and post-acute care sector, and to send thanks and appreciation to healthcare heroes.
Visitation, Observation, and Testing

Limiting visitation to compassionate care visits has been vital in mitigating the spread of COVID-19 in all healthcare settings and reducing the death rate among older and medically challenged Marylanders who live in nursing homes or receive care in hospitals. As we all know, older individuals and those with pre-existing conditions are most at risk of severe illness or death due to COVID-19.

While it was difficult, and everyone wanted to visit loved ones in healthcare settings across the care continuum, nobody wanted to be the person to spread the virus or cause an outbreak among our most vulnerable populations and those who provide their care.

Last week Governor Hogan and the Maryland Department of Health (MDH) released updated orders on nursing home matters and various health care matters. The updated amended orders align state visitation guidelines with those of the Centers for Medicare and Medicaid Services (CMS) beginning March 1, 2021.

The alignment of visitation with CMS guidelines should result in more centers being able to allow visitation. It is important to remember that compassionate care visits had been previously and continue to be permitted. Regarding the updated MDH visitation orders, which again go in to effect March 1, some points will increase visitation and some points will impede visitation in our setting:
 
  • The modification of percentage caps of visitors linked to the size of a specific skilled nursing and rehabilitation center, its number of licensed beds, and the community's positivity rate will mean that more people will be able to visit with proper PPE and precautions.
 
  • However, linking visitation to the CMS guidance will continue limiting visitation because the CMS requirement for a facility to be totally COVID free for 14 days is still in place. We need the federal government to distinguish that rule, which includes one single case, to exclude workers who do not directly interact with patients. 

  • HFAM continues to advocate for clinically-driven visitation policies and will keep working closely with our MDH colleagues at the state level and with the American Health Care Association/National Center for Assisted Living (AHCA/NCAL) at the federal level.
 
  • My genuine advice to healthcare heroes and leaders providing quality care to Marylanders in need is to continue being clinically driven AND to increase the number of compassionate care visits.
 
NOTE: Another part of the orders last week was policy guidance making barbers and cosmetologists more available in our setting with proper precautions. I hope and pray that centers can make that happen; a haircut or style can really lift spirits. 

Also, CLICK HERE for Baltimore Sun coverage of the orders and related issues.

We had a frank and productive conversation last week with MDH leaders on the new orders. Both the new orders and the dialogue are appreciated. Given the decline of COVID-19 cases and the vaccination of the majority of residents and patients, we continue to press for new observation and testing guidelines that are clinically driven. That said, Maryland testing frequency and cohorting orders were developed based on earlier guidelines from the Centers for Disease Control and Prevention (CDC).
 
Since the earlier Maryland orders, CDC cohorting (observation) requirements have been reduced to seven and ten days, depending on the setting. Now may be the time to reduce the cohorting (observation) requirement from fourteen to ten days in Maryland skilled nursing and rehabilitation centers—especially since the new health care matters order will increase non-emergency procedures in hospitals.

Earlier orders regarding testing in our setting were rightfully linked to community positivity rates (at a time when those rates were much higher) and did not take vaccination in to account. In November 2020, Maryland orders linked testing directly to the community positivity rate. Now may be the time to reduce employee testing to once per week.
Vaccine Distribution
Going forward, broad vaccine distribution and federal vaccine supply remain causes for concern. As you know, vaccination in skilled nursing and rehabilitation centers, assisted living communities, and other senior housing settings has been implemented through the federal Pharmacy Partnership for Long-Term Care Program. This program provides all management of the COVID-19 vaccination process through three vaccine clinics at each participating long-term care facility.

As many facilities are closing in on their third clinic, questions have arisen whether residents and staff will be able to receive a first dose of the vaccine at the third and final clinic. Over the last several weeks, HFAM has been working with the Maryland Department of Health (MDH) on a COVID-19 vaccination plan moving forward once the federal CVS/Walgreens clinics are over. We have long advocated that our sector's institutional pharmacies should be allocated COVID-19 vaccines and hold periodic clinics in our centers. It seems the that the Centers for Disease Control and Prevention (CDC) is moving in that direction. 

Recently, CDC announced that the policy is to optimize vaccine access for residents and staff, which means delivering the first dose of either vaccine at the third clinic. However, the pharmacies will defer to state/jurisdictional guidance. So, if state health departments decide not to allow first doses at the third clinic in all cases, for example, the pharmacy will follow that guidance.  

If residents and staff receive the first dose of the vaccine at the third clinic, it’s important to determine how they will access the second dose. For providers that need assistance securing the second dose on behalf of staff or residents, CDC is recommending that providers reach out to their public health department on vaccine availability and to call on each of the retail pharmacies involved in the CDC’s Federal Retail Pharmacy Program.

We have had several calls with state leaders on vaccination and together, we will continue to push forward in advocating to ensure that all are vaccinated, even after the federal vaccine clinics end.

Again, one major concern remains to be the federal supply of vaccines. This CDC guidance mirrors the path forward we have been advocating for here in Maryland, and continued partnership with state leadership will be essential. It is also critical that Maryland hospitals administer the first COVID-19 vaccine dose before discharging a patient to a SNF or ALF.
Appreciation for Healthcare Heroes

As always, the HFAM team and I thank healthcare heroes for all that they are doing in the fight against COVID-19. Positive cases in the community, as well as in skilled nursing and assisted living centers, are currently trending down. The downward trend in cases is partly due to the correlation between the community positivity rate and the positivity rate in healthcare centers; however, a large part of the downward trend is due to continued infectious disease control protocols. Vaccination rates, especially among residents and patients, are also a factor in the downward trend of positive cases in our sector.
Continued Vigilance
 
The current decline of COVID-19 positivity rates is not permission to let our guard down. At home, at work, and in the community, we all must remain vigilant in our fight against this virus.
 
Clinical experts are very concerned about the current spread and incubation of COVID-19 variants. To the extent that Maryland and the nation can increase vaccine supply and vaccinate more people, the risk of increased cases, hospitalizations, and deaths can be mitigated. In the meantime, clinicians and others have learned much in the fight against COVID-19 and we are reminded to focus on what is in our control.

Onward together!

Be well,
Joe DeMattos
President and CEO
ABOUT HFAM

The Health Facilities Association of Maryland (HFAM) is the oldest and largest nationally affiliated long-term and post-acute care association in the state. HFAM represents over 170 skilled nursing centers and assisted living communities in Maryland, as well as nearly 80 associate businesses that offer products and services to health care providers. Our members provide services and employ individuals in nearly every jurisdiction in the state.

Thousands of Marylanders across the state depend on the high-quality care and services that our members offer every day. HFAM skilled nursing and rehabilitation center members provide the majority of post-acute and long-term care to Marylanders in need: 6 million days of care across all payer sources annually, including more than 4 million Medicaid days of care and one million Medicare days of care.

Visit our website to learn more.