ATTENTION: COVID-19 UPDATE
March 13, 2020
As communicated yesterday, this week Governor Cooper declared a state of emergency related to Coronavirus Disease 2019 (“COVID-19). We have assembled and attached guidance from the North Carolina Department of Health and Human Services (“NCDHHS”), the Centers for Medicare & Medicaid Services (“CMS”), and the Centers for Disease Control and Prevention (“CDC”) for dealing with COVID-2019 in Long-term Care.
Last evening, NCDHHS revised it's "
Interim Long-Term Care Setting Guidance for Residents with Suspected or Confirmed Coronavirus Disease 2019 (COVID-19) and Their Caregivers,"
which can be found
Here
You can view the most recent status of COVID-19 in North Carolina at the NCDHHS website
Here.
Based on available information, COVID-19 appears to disproportionately impact the frail and elderly which, combined with its high infection rate, makes it a particularly dangerous threat in congregate care settings. The following news out of Italy is particularly troubling for those providing services to our older citizens:
Italy’s Civil Protection Chief and Coronavirus Emergency Commissioner Angelo Borrelli said Tuesday that said that 45% of those that have died were aged 80-89 and 32% were in their 70s, 14% were over 90, 8% were in their 60s and 2% were aged 50 to 59.
The attached guidance addresses at least five crucial factors members must address to protect their residents, staff, and visitors in their facilities:
· Policies and procedures
· Infection control and prevention practices
· Limitation of visitors and other individuals in facilities
· Coordination with local health departments, NCDHHS, CDC, and other state, local and federal agencies
· Staff Training
Policies and procedures
Facilities must review their infection control policies and procedures to ensure that they adequately address topics such as cleaning and sanitation, blood and bodily fluid precautions, and accessibility of infection control supplies.
Infection control and prevention practices
Facilities should immediately implement infection control practices to (1) prevent the introduction of respiratory germs into your facility; (2) prevent the spread of respiratory germs within your facility; and (3) prevent the spread of respiratory germs between facilities. The current guidance from the CDC is attached setting out basic strategies. We recommend that you consider following the attached CMS guidance for nursing homes which provides more detailed guidance, particularly related to monitoring and restricting visitors and staff and for transfers between facilities.
Limitation of visitors and other individuals in facilities
This is perhaps the most difficult area to address. NCDHHS Adult Care Licensure Section (“ACLS”) guidance “
recommends that all facilities that serve as residential establishments for
high risk persons
should limit visitors and restrict all visitors who have respiratory illness or potential exposure to COVID-19.” See “
Guidance for Infection Control and Prevention of Coronavirus Disease 2019 (COVID-19) in Adult Care Homes and Family Care Homes.” The ACLS guidance provides some details on monitoring and limiting visitors and for monitoring and restricting staff but this guidance leaves much room for interpretation. The attached CMS guidance for nursing homes provides much more detailed guidance. While we certainly recognize that adult care homes (“ACHs”) are not nursing homes, we believe that the threat posed by COVID-19 is likely to be as high in ACHs as in nursing homes and that following the clear guidance issued by CMS would be reasonable under the circumstances.
CMS guidance revolves around three definitions:
Restricting
means the individual should not be allowed in the facility at all, until they no longer meet the criteria above.
Limiting
means the individual should not be allowed to come into the facility, except for certain situations, such as end-of-life situations or when a visitor is essential for the resident’s emotional well-being and care.
Discouraging
means that the facility allows normal visitation practices (except for those individuals meeting the restricted criteria), however the facility advises individuals to defer visitation until further notice (through signage, calls, etc.).
Facilities should monitor and restrict
visitors and staff
who meet the following criteria:
1. Signs or symptoms of a respiratory infection, such as fever, cough, shortness of breath, or sore throat.
2. In the last 14 days, has had contact with someone with a confirmed diagnosis of COVID-19, or under investigation for COVID-19, or are ill with respiratory illness.
3. International travel within the last 14 days to countries with sustained community transmission. For updated information on affected countries visit:
4. Residing in a community where community-based spread of COVID-19 is occurring.
Remember that “restrict” means “
the individual should not be allowed in the facility at all, until they no longer meet the criteria above
.”
In addition, CMS guidance recommends that visitation should be limited or discouraged as described below:
a)
Limiting:
For facilities that are in counties, or counties adjacent to other counties where a COVID-19 case has occurred
, we recommend restricting visitation
(except in certain situations as indicated above). You can view the most recent cases and map of COVID-19 cases in North Carolina
Here
. Please note the map changes daily depending on where new cases of COVID-19 are identified. Currently, COVID-19 has been detected in the following counties:
- Wake County - 8 cases
- Durham County - 1 case
- Chatham County - 1 case
- Johnston County - 1 case
- Onslow County - 1 case
- Forsyth County - 1 case
- Cabarrus County - 1 case
- Mecklenburg County - 2 cases
As you can see, the virus is not concentrated in one area in North Carolina but has been identified in the Piedmont, Central and Eastern areas.
For example, a daughter who visits her mother every Monday, would cease these visits, and limit her visits to only those situations
when her mom has a significant issue. Also, during the visit, the daughter would limit her contact with her mother and only meet with her in her room or a place the facility has specifically dedicated for visits.
Facilities should also carefully consider protocols for transfers between facilities, transfers to hospitals, and visits to doctors and other care providers. Telemedicine should be considered whenever possible.
In sum, the CMS guidance provides detailed information that facilities should carefully review and implement as appropriate.
Coordination with local health departments, NCDHHS, CDC, and other state, local and federal agencies
Facilities should closely monitor information disseminated by local health departments, NCDHHS, CDC, CMS, and other agencies. Any suspected case of COVID-19 should be reported immediately to local health department officials. Telephone numbers for the local health department should be posted clearly visible to all staff.
Staff Training
In addition, facilities should review and train staff using the CDC’s Infection preventionist training found at
https://www.cdc.gov/longtermcare/index.html
.
All staff should be trained on screening and visitation policies and who to notify in case of a suspected case of COVID-19.
Conclusion
ACHs are on the front lines of fighting COVID-19. ACHs should not assume that guidance issued by any one agency is definitive. All providers should monitor the various sources described in this guidance and the
Attached Documents (click here)
Jeff Horton, Executive Director
