Along with his announcement, the Governor issued a revised Proclamation rolling back, limiting, or prohibiting a number of activities that had been allowed, including indoor restaurant-style dining, group activities, and visitation.

In addition, an easy reference Guidance was also issued. The Governor’s press release provides additional information on the new restrictions.

Many members are questioning whether the Proclamation prohibits the use of facility dining rooms. The confusion stems from the fact that the Proclamation mentions “bars and restaurants” but does not clarify if congregate settings like facility dining rooms or dormitory/school cafeterias should be closed. We would note, however, that the Proclamation does mention (in the section referencing “In-Store Retail”) that “common/congregate seating areas and indoor dining facilities such as food courts are closed.” We expect that the Governor’s office will tell us that our skilled nursing, assisted living, and senior living dining rooms will need to close, but we are not going to assume that will happen. We are currently engaged in ongoing discussions with the Governor’s office and we are trying to get answers. As soon as we have answers, we will pass the information on to you. Please note that the “restaurant and bar” closure provisions do not go into effect until 12:01 AM Wednesday, November 18, 2020. We hope to have further clarification before then.

Members also have questions about the Governor’s visitation provisions. In his Proclamation, the Governor directs that: “Outdoor visits are permitted. Indoor visits are prohibited, but individual exceptions for an essential support person or end-of-life care are permitted.” At first glance this would appear to be a loosening or relaxing of the visitation provisions, but we do not believe that to be the case. Currently, “essential support persons” can only visit a facility that is in Phase 2 or higher. That limitation remains in effect.

In addition, the Governor’s recent Proclamation also appears to impose a more restrictive standard on “compassionate care” visits. Before the Governor’s recent Proclamation, Phase 1 indoor visitation was prohibited, except for “Compassionate care situations restricted to end-of-life and psycho-social needs.” The Governor’s more recent Proclamation is more stringent, eliminating any reference to “compassionate care” and “psycho-social needs” and instead clearly stating “individual exceptions for an essential support person or end-of-life care are permitted.”

The Governor’s recent Proclamation does not give the “essential support person” unhindered access and carte blanche to come and go at will. The current “Safe Start” provision pertaining to “essential support persons” for both assisted living and skilled nursing are still in effect.

WHCA is working diligently to seek clarification and advocate on behalf of our members and the residents they serve. We will pass on any clarification as soon as it becomes available. Please continue to reach out to Elena Madrid or Vicki McNealley with questions.

In a Dear Administrator letter dated November 13, 2020, all providers are given insight on risk assessment during holiday travel. The letter reminds providers of the importance of using the risk assessment to determine COVID-19 exposure risk in long term care facilities. The letter provides links specifically for assisted living, skilled nursing, and certified community residential services and supports. If anybody on your team plans to engage in holiday travel, please share this insight with them to ensure they mitigate risk of exposure. If any resident plans to leave the facility for any reason, ensure you use the risk assessment to determine safety measures to minimize infection spread upon returning to the facility.

In a Dear Administrator letter dated October 9, 2020, and amended November 13, 2020, Residential Care Services (RCS) informs all providers that full reimplementation of inspection and investigation for RCS is postponed indefinitely. The letter provides insight and background for the decision. The letter also explains that the Reimplementation of Inspection and Investigation Activity for RCS document dated November 1, 2020, is available for providers to review in preparation for when full survey activity does resume.

You are invited to a webinar on November 19, 2020, at 6 PM hosted by the Washington Society of Post Acute and Long Term Care Medicine (WA-PALTC). The webinar, Testing for COVID in Long Term Care: What is the best way to do it? will be presented by Charissa Fotinos, MD, Deputy Chief Medical Officer, Washington Health Care Authority; Cyndee Jones, MSHCA, CLS, Director Lab & Blood Services, Swedish; James Lewis, MD, Infectious Disease Specialist, King County Department of Health, and moderated by Sabine von Preyss-Friedman, MD, CMS, Washington Society of Post-Acute and Long Term Care Medicine. Click here to register.

There are currently 30 spots remaining. If your facility would like to participate, click here to register today.

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.