COVID-19 UPDATE #246
May 27, 2022
WORKFORCE VACANCY SURVEY | CRITICAL INFORMATION FOR POLICYMAKERS
It is extremely important for policymakers to have a real perspective on LTC workforce challenges. Please take 20 minutes today to submit data to complete the Spring 2022 WA Health Sentinel Network before JUNE 6. Click here to complete the survey.

WHCA uses Sentinel Network data to make the case for funding and regulatory relief for skilled nursing and assisted living providers. While workforce waivers intended to provide relief from regulatory requirements related to the staffing crisis are still in effect, there are continued pressures to reimplement such standards. For skilled nursing facilities, work is already in progress to develop regulations to reimplement the 3.4 hour staffing requirement per resident day and the 24-hour RN training requirement. Please respond today so that we have credible, third-party data to use with policymakers.

Your feedback is critical and confidential. Details you provide, including recruitment challenges, are confidential so you can share freely and securely. Don’t let your current health workforce needs go unaddressed!
SURVEY REGARDING HOME CARE AIDE AND CERTIFIED NURSING ASSISTANT REQUIREMENTS IN ASSISTED LIVING
The Department of Social and Health Services (DSHS), in coordination with the Department of Health (DOH), is preparing to assist providers and their staff in meeting long term care worker requirements before the eventual end of the waivers related to the public health emergency. As part of this work, we need to assess how many long term care workers need to complete training, testing, or certification from the Department of Health.

These agencies are seeking feedback from assisted living facilities via completion of a survey to provide information on the number of staff that need to complete these requirements. This will help the departments to target resources and create appropriate timelines for reinstatement of the requirements. If you are an assisted living provider, please complete this survey today!
DEAR ADMINISTRATOR LETTERS TO NURSING HOMES NOTIFY OF EMERGENCY RULES EXTENSIONS
Dear Administrator Letter Regarding Disaster and Emergency Preparedness and Resident Rooms
In a Dear Administrator letter dated May 26, 2022, skilled nursing providers are notified that the Centers for Medicare and Medicaid Services (CMS) released QSO-22-15-NH & NLTC & LSC, announcing the lapse of the CMS 1135 blanket waiver related to quality assessment and assurance requirements on May 7, 2022. CMS continued the federal waivers related to fire drills and windows in each resident room. The department filed WSR 22-11-088 effective May 7, 2022, which cancels and supersedes WSR 22-04-038, reimplementing the requirements related to quality assessment and assurance under WAC 388-97-1760 for consistency with federal requirements. In addition, WSR 22-11-088 extends the amendment of the disaster preparedness and resident room rules to continue to align Washington State nursing home rules with federal rules.

The following amendments continue to be suspended under this rule filing effective Maya7, 2022:
  • WAC 388-97-1740 to remove the requirement for periodic fire drills. Documentation on training and responding to a fire is still required.
  • WAC 388-97-2400 to waive the requirement for a transparent glass window. This will increase the ability for facilities to temporarily increase capacity by utilizing windowless space for resident rooms.

Dear Administrator Letter Regarding Requirements Related to PASRR
Another Dear Administrator letter dated May 26, 2022, informs skilled nursing providers The Centers of Medicare and Medicaid Services (CMS) announced the lapse of CMS 1135 waiver related to resident groups on May 7, 2022. The department filed WSR 22-11-078 effective May 7, 2022, to rescind the previous emergency rule filing (WSR 22-09-014), removing the language related to resident groups, and continuing to waive the rules related to PASRR in order to align the federal and state regulations.

WACs 388-97-1915 and -1975 continue to be amended under emergency rules to permit the level I PASRR screening, and if needed, the level II evaluation to occur up to 30 days after admission. 

If you have questions about either of these topics, please email Molly McClintock, Nursing Home Policy Program Manager or call her at (360) 742-6966.
UPDATES TO HEALTH EMERGENCY LABOR STANDARDS ACT EMERGENCY RULES AND GUIDANCE
L&I has updated emergency rules in effect during declared public health emergencies including the COVID-19 pandemic. To help explain how these rules impact business and workers, L&I has published updated guidance Questions and Answers: Reporting and Notification Requirements of HELSA and PPE Use.

The emergency rule, updated April 2022, outlines requirements for all employers and healthcare facilities (as defined by RCW 9A.50.010):
  • All employers must allow employees and contractors to voluntarily use personal protective equipment.
  • Non-healthcare employers must notify employees, and may need to notify other entities, in writing of potential exposures within one business day.
  • Employers of healthcare facilities must notify any employee with known or suspected high-risk exposure to the infectious or contagious disease within 24 hours.
  • With employee authorization, notification must also be sent to the employee’s union representative (if applicable) within 24 hours and
  • Employers with more than 50 covered employees at a workplace or job site must report infectious or contagious disease outbreaks to L&I.

The emergency rules are also provided in several languages If you have employees, coworkers, or others who would be better served by a translated version of the document.
FIT TEST TRAINING ANNOUNCEMENT
Learn how to conduct your own respirator fit test to help protect your staff and stay in compliance with the respiratory protection regulations. The Department of Health (DOH) Occupational Health Team has started training long term care facilities to conduct their own fit test.

There are three steps:
  1. Complete the pre-training work before attending the Fit Test Training webinar.
  2. Attend the Fit Test Webinar and participate.
  3. Complete the Hands-on Fit Test Training with the DOH fit test vendor.

If you are interested in learning how to conduct your own fit test, please visit www.doh.wa.gov/ltcrpp, go to the Fit Test Training page for more information and sign up. The free 3M online medical evaluation is still available for a limited time. Email HAI-FitTest@doh.wa.gov with *MEDICAL EVALUATION* in the subject line for information on how to get signed up for the medical evaluation online system.  
WA-PALTC PROVIDES IMPORTANT UPDATE ON REVIEW OF TREATMENT FOR COVID-19
As you aware, we are in the middle of another COVID surge. Fortunately, we are not in the beginning of the pandemic and we now have sufficient PPE, vaccines, and treatment options. WA-PALTC seeks to review the NIH treatment guidelines for COVID-19. It is important to treat all patients who have symptomatic COVID-19.

Who should be treated for COVID?
All patients are at high risk for worsening of disease. All patients who have mild symptoms or worse should be treated.

How is mild and moderate COVID defined?
Here are NIH definitions:
  • Mild Illness: Individuals who have any of the various signs and symptoms of COVID-19 (e.g., fever, cough, sore throat, malaise, headache, muscle pain, nausea, vomiting, diarrhea, loss of taste and smell), but who do not have shortness of breath, dyspnea, or abnormal chest imaging.
  • Moderate Illness: Individuals who show evidence of lower respiratory disease during clinical assessment or imaging and who have an oxygen saturation (SpO2) ≥94% on room air at sea level.
  • Severe Illness: Individuals who have SpO2 <94% on room air at sea level, a ratio of arterial partial pressure of oxygen to fraction of inspired oxygen (PaO2/FiO2) <300 mm Hg, a respiratory rate >30 breaths/min, or lung infiltrates >50%.

How should symptomatic residents be treated?
Per the treatment guidelines from the NIH, Paxlovid is the most effective, first line treatment; however, this drug has drug interactions especially with anticoagulants and seizure meds and needs a reduced dosage in patients with renal disease. The Liverpool COVID interaction site is very helpful and can assist with drug interaction. Please contact your pharmacist for assistance with prescribing Paxlovid. Bebtelovimab is probably the second choice. It is a one-time injection. Again, please coordinate with your pharmacist prior to any treatment.

What about anticoagulation?
Early administration of aspirin in the hospital course of 112,269 patients with moderate COVID-19 improved survival without an increased risk of hemorrhagic complications in a cohort study. This effect is even more pronounced in patients 60 years or older and in those with at least one comorbidity. Consider this for moderately ill patients.
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.