COVID-19 UPDATE #218
January 11, 2022
HOW TO IMPLEMENT CDC CONTINGENCY AND CRISIS STRATEGIES TO MITIGATE STAFFING SHORTAGES
Many long term care facilities around the country are struggling with staffing shortages due to the rapid spread of the Omicron variant. The Centers for Disease Prevention and Control (CDC) provides contingency and crisis capacity standards to help mitigate staffing shortages created by staff testing positive or PPE shortages. 

There is no standard template or established process to move between these standards. Rather, CDC has left it up to each health care organization who knows its situation and needs the best to determine based on patient acuity, staffing needs, staffing levels, unique staffing positions, backup staffing availability, patient volume, patient needs, equipment and resource availability, etc. However, the lack of specific guidance leaves many providers uncertain on how to utilize these standards. 

As you determine whether you need to activate these standards, we recommend that when you transition from conventional standards to contingency or crisis: 
  • ​Contact your local or State Department of Health (DOH) and the State Survey Agency (SSA) to let them know why you are taking these actions, your staffing issues, and all the actions you have and will be taking to find staff and meet residents’ needs.  
  • Document why, when, how, and where it is making these transitions to contingency or crisis standards, as well as what aspects of the CDC standards it will be adopting.
  • Document all outreach/efforts to find staff and communication with the local or State DOH and SSA. 
  • Notify staff that you have made a transition and what it means to them. 

Note that as you are considering whether to deploy these contingency and crisis standards of care, you may also need to consider pausing admissions and/or closing units/wings/floors to reallocate resources or, if all else fails, transferring residents to surrounding facilities or hospitals. If transferring residents is considered, you should contact the state DOH, the hospital(s), and ombudsman. The approaches used should also be consistent with the emergency preparedness plan. Some steps to help identify additional staff include: 
  • ​Put in a request to the local governor’s office for national guard support. 
  • Call your Ombudsman to ask for help in securing staffing help from the state.  
  • Reach out to your local health care coalition.  
  • Reach out to temporary staffing agencies.  
  • Reach out to other health care providers (e.g., hospitals and LTC providers). 

Read more.
ARGENTUM PRESSES BIDEN FOR TESTS, BOOSTER HELP, AND FINANCIAL RELIEF
Argentum sent a letter to President Biden and HHS Secretary Becerra, imploring the administration to directly supply senior living facilities with COVID-19 testing supplies, resuming a federal program for vaccine and booster administration, and reiterating the need for targeted federal financial relief.

Argentum’s letter comes as the need for tests has grown rapidly with the dramatic increase in cases spurred by the Omicron variant. While senior living facilities had previously received supplies of tests, those have now largely been depleted and acquiring additional supplies has been very difficult for communities. As we note in our letter, the tests are needed to better track and mitigate the spread of COVID-19, ensure staff are able to return to the workforce as quickly as possible based on the recent CDC guidance, and also to support visitation. Read more.
WA SNFs MUST COMPLY WITH CMS VACCINE REQUIREMENTS
On December 28, 2021, CMS released guidance via QSO-22-07-ALL regarding health care staff COVID-19 vaccination. The CMS memo outlines the guidance and survey procedures for state agencies to assess facility compliance with the regulatory requirements. While these requirements do not currently apply to the 25 states involved in legal action regarding the federal vaccine mandate, they do apply to Washington’s skilled nursing facilities. Washington State’s vaccine mandate predated these requirements and gave facilities a head start on the vaccination of staff. However, skilled nursing facilities will be surveyed to the federal requirements. It is important that facilities read the memo in its entirety as well as the LTC attachment for additional information regarding deadlines, definitions and details.

A brief synopsis of the F888 requirements regarding the CMS vaccine mandate is below:

The facility must develop and implement policies and procedures to ensure that all staff are fully vaccinated for COVID-19. Regardless of clinical responsibility or resident contact, the policies and procedures must apply to the following facility staff, who provide any care, treatment, or other services for the facility and/or its residents:
  • Facility employees.
  • Licensed practitioners.
  • Students, trainees, and volunteers; and
  • Individuals who provide care, treatment, or other services for the facility and/or its residents, under contract or by other arrangement.

The policies and procedures of this section do not apply to the following facility staff:
  • Staff who exclusively provide telehealth or telemedicine services outside of the facility setting and who do not have any direct contact with residents and other staff specified in paragraph above; and staff who provide support services for the facility that are performed exclusively outside of the facility setting and who do not have any direct contact with residents and other staff.

The policies and procedures must include, at a minimum, the following components:
  • A process for ensuring all required staff (except for those staff who have pending requests for, or who have been granted, exemptions to the vaccination requirements, or those staff for whom COVID-19 vaccination must be temporarily delayed, as recommended by the CDC, due to clinical precautions 2 and considerations) have received, at a minimum, a single-dose COVID-19 vaccine, or the first dose of the primary vaccination series for a multi-dose COVID-19 vaccine prior to staff providing any care, treatment, or other services for the facility and/or its residents; However, please note that our state vaccine mandate requires all staff to be fully vaccinated prior to starting work at the facility and any resident contact.
  • A process for ensuring that all staff are fully vaccinated for COVID-19, except for those staff who have been granted exemptions to the vaccination requirements of this section, or those staff for whom COVID-19 vaccination must be temporarily delayed, as recommended by the CDC, due to clinical precautions and considerations.

The facility must also be able to demonstrate a process for ensuring the implementation of additional precautions, intended to mitigate the transmission and spread of COVID-19, for all staff who are not fully vaccinated for COVID-19, as well as having a process for tracking and securely documenting the COVID-19 vaccination status of all staff. The requirement states the facility’s process must also track and securely document the COVID-19 vaccination status of any staff who have obtained any booster doses.
Additional requirements necessitate the facility have a process by which staff may request an exemption from the COVID-19 vaccination requirements and for facility tracking and securely documenting this information for those staff who have requested and received an exemption.

All documentation, which confirms recognized clinical contraindications to COVID-19 vaccines, and which supports staff requests for medical exemptions from vaccination must be signed and dated by a licensed practitioner, acting within their respective scope of practice. That documentation must contain the following elements:
  • All information specifying which of the authorized COVID-19 vaccines are clinically contraindicated for the staff member to receive and the recognized clinical reasons for the contraindications; and
  • A statement by the authenticating practitioner recommending that the staff member be exempted from the facility’s COVID-19 vaccination requirements for staff based on the recognized clinical contraindications.

The facility must also have a process for ensuring the tracking and securing of documentation of the vaccination status of staff for whom COVID-19 vaccination must be temporarily delayed, as recommended by the CDC, due to clinical precautions and considerations, including, but not limited to, individuals with acute illness secondary to COVID-19, and individuals who received monoclonal antibodies or convalescent plasma for COVID-19 treatment.

To help members in the impacted states comply with the vaccine mandate, AHCA/NCAL has updated its template policies and procedures, available on the COVID-19 website under the Vaccines section. If you have questions, please email Elena Madrid or call her at (800) 562-6170, extension 105.
DEAR ADMINISTRATOR LETTER EXPLAINS NEW "OPERATION EXPANDED TESTING" PROGRAM
In a Dear Administrator letter dated January 7, 2022, all providers are notified The United States Department of Health and Human Services (DHHS) and Department of Defense (DoD) are funding a no-cost COVID-19 testing program called “Operation Expanded Testing.” Supplies for self-swab polymerase chain reaction (PCR) tests and implementation support for routine testing is available to long term care facilities and homes through the regional contractor, PerkinElmer. PerkinElmer provides delivery of test kits, processing of tests at their labs, and a built-in system for reporting test results.

To qualify for this program, the long term care facility or home must be located in a region with a high Social Vulnerability Index (SVI) (defined as 0.5 or higher.) The SVI for your region can be found by following this link to the CDC’s SVI Interactive Map. To use the site, zoom in to your general location on the map, click on the magnifying glass search icon in the upper right corner of the map and enter your facility or home address. A black box will pop up with the region’s SVI index. If it is 0.5 or higher, your facility is qualified.

Facilities can apply and find more information about the program at Home – Let’s End This Together.
ADDITIONAL RESOURCES
WHCA continues to post resources and information as it becomes available on our website. If you have questions or need additional information, please call the WHCA office at (800) 562-6170.