Coronavirus Update #16
Videos & FAQs for Seniors, Communal Dining Guidance, Update on 3-Day Stay Waiver
Videos & FAQs

The Maryland Department of Health and Maryland Department of Aging have developed FAQ documents and a series of audio and video messages directed at seniors on a variety of topics related to the current COVID-19 pandemic. Please use these materials to help communicate with residents.

Topics include:
  • Use of the dining hall
  • Home sanitation
  • Senior Call Check-in
  • Senior center closings
  • How to keep informed

Possible uses for these materials include:
  • Closed circuit television
  • Lobby screens
  • Social media platforms
  • E-newsletters

Click the below buttons to view and download the FAQs and audio/video messages.
If you have questions about how to use the materials, please contact pio.mema@maryland.gov .
Communal Dining Guidance

CMS’s memo dated March 13, 2020 includes guidance to “cancel communal dining and all group activities” in your skilled nursing facility. (Please note: we also strongly encourage assisted living communities to abide by this recommendation.) Implementing this can be a challenge and will likely require changes in staffing patterns and enlisting other staff in the facility in order to accomplish.

Facilities should take all reasonably available steps to adhere, given the dire consequences of the spread of COVID-19 among our resident population. How this is implemented must be viewed on a facility-by-facility and day-to-day basis depending on physical plant, staff availability, and resident needs.

A key reason for the recommendation to cancel communal dining is linked to the concept of social distancing (e.g., limiting people being in close proximity to each other for periods of time; ideally people should keep about six [6] feet apart). Social distancing is recommended broadly across the public and recommended by CMS for facilities regarding resident interactions. Communal dinning is a common group activity that places residents in close proximity to each other. This can spread respiratory viruses.

The experience in the Seattle, Washington area suggests the spread may have been facilitated by group activities, including perhaps communal dinning.

This virus is now reported in 49 states. You should assume it is already in your surrounding community, whether or not it has been confirmed, due to lack of testing to-date.  Implement social distancing in your dining practices. Recommended approaches:

  • Provide in-room meal service for those that are assessed to be capable of feeding themselves without supervision or assistance.

  • Identify high-risk choking residents and those at-risk for aspiration who may cough, creating droplets. Meals for these residents should ideally be provided in their rooms; or the residents should remain at least six (6) feet or more from others if in a common area for meals, and with as few other residents in the common area as feasible during their mealtime. Staff should take appropriate precautions with eye protection and gowns given the risk for these residents to cough while eating.

  • If residents need to be brought to the common area for dining, do this in intervals to maintain social distancing.

  1. Attempt to separate tables as far apart as possible; at least six (6) feet if practicable.
  2. Increase the number of meal services or offer meals in shifts to allow fewer residents in common areas at one time.
  3. Ideally, have residents sit at tables by themselves to ensure that social distancing between residents can be maintained, or depending on table and room size.
  4. If necessary, arrange for meal sittings with only two (2) residents per table, focusing on maintaining existing social relationships and/or pairing roommates and others that associate with each other outside of mealtimes.

  • Residents who need assistance with feeding should be spaced apart as much as possible, ideally six (6) feet or more or no more than one person per table (assuming a standard four (4) person table). Staff members who are providing assistance for more than one resident simultaneously must perform hand hygiene with at least hand sanitizer each time when switching assistance between residents.

  • The CMS memo also emphasizes no visitation of non-essential health care personnel, unless for compassionate care visits (end-of-life). Facilities may need to consider use of volunteers or other paid personnel to accomplish food service, which can be viewed as essential and not as visitors. Note: they must undergo screening upon entry and adhere to frequent handwashing or use of alcohol-based hand rub.

In general, facility life will have to adjust significantly during this viral breakout with a primary focus on:

  1. necessary medical treatment;
  2. hygiene;
  3. hydration; and
  4. meal service

as these will take more, if not all of your staff’s time. As with all other guidance during the COVID-19 pandemic, handwashing and hygiene before, during and after meals is imperative.
Please email COVID19@ahca.org for additional questions, and visit
www.ahcancal.org/coronavirus for additional information and resources.
Three-Day Rule Waiver Update

On March 14, the Centers for Medicare and Medicaid Services (CMS) issued two waivers to aid skilled nursing facilities in addressing the national COVID-19 outbreak. CMS is waiving both the 3-Day Stay and Spell of Illness requirements – nationally

These waivers mean that skilled nursing facility (SNF) care without a 3-day inpatient hospital stay will be covered for beneficiaries who experience dislocations or are affected by the COVID-19 outbreak. Due to the current crisis, CMS also is utilizing the authority under section l8l2(f) providing renewed SNF coverage to beneficiaries without starting a new spell of illness and allowing them to receive up to an additional 100 days of SNF Part A coverage. More detail and background information are provided below. 

Overview 
When the President declares a disaster or emergency under the Stafford Act or National Emergencies Act and the U.S. Department of Health and Human Services (DHHS) Secretary declares a public health emergency under Section 319 of the Public Health Service Act, the Secretary is authorized to take certain actions in addition to regular authorities. For example, under section 1135 of the Social Security Act, the Secretary may temporarily waive or modify certain Medicare, Medicaid, and Children’s Health Insurance Program (CHIP) requirements to ensure that sufficient health care items and services are available to meet the needs of beneficiaries. Today, DHHS has waived the critical SNF provisions. 

3-Day Stay Waiver
Section 1861(i) of the Act permits Medicare payment for SNF care only when a beneficiary first has an inpatient hospital stay of at least three consecutive days. Section 1812(f) of the Act allows Medicare to pay for SNF services without a 3-day qualifying stay if the Secretary finds that doing so will not increase total payments made under the Medicare program or change the essential acute-care nature of the SNF benefit. Based upon the President’s actions and the Secretary’s authority under Section 1135 and Section 1812(f), SNF care without a 3-day inpatient hospital stay will be covered for beneficiaries who experience dislocations or are affected by the emergency.  

Spell of Illness Waiver
In addition, CMS is recognizing special circumstances for certain beneficiaries who, prior to the current emergency, had either begun or were ready to begin the process of ending their spell of illness after utilizing all of their available SNF benefit days. Existing Medicare regulations state that these beneficiaries cannot receive additional SNF benefits until they establish a new benefit period (i.e., by breaking the spell of illness by being discharged to a custodial care or noninstitutional setting for at least 60 days). Due to the current crisis, CMS also is utilizing the authority under section l8l2(f) providing renewed SNF coverage to beneficiaries without starting a new spell of illness and allowing them to receive up to an additional 100 days of SNF Part A coverage. The policy applies only for those beneficiaries who have been delayed or prevented by the emergency itself from beginning or completing the process of ending their current benefit period and renewing their SNF benefits. 
As a reminder, we continue to advise:

  • The #1 action you and your teams can do right now is keep all people with cold/flu symptoms out of your centers.

  • Employees simply cannot come to work if they are symptomatic.

  • Be prepared to over-communicate with staff, residents, patients, and families.

  • Inventory supplies and medication - especially infectious control gear.

  • Review your policies and training.

  • Closely monitor the health of your patients, residents, and staff.

  • Establish lines of communication with your hospital partners, local and state health officials.
HFAM continues to monitor the COVID-19 situation with our state and national partners and will keep members informed. Additional information for healthcare professionals can be found on the  CDC  and on the   MDH   websites.