The availability and supply chains for PPE have increased greatly in 2021. As the supply chains have increased PPE access to facilities, each facility’s use of PPE should have moved towards consistent conventional strategies. The facility use of conventional PPE strategies is becoming a focus of regulatory and state agencies including DSHS/RCS, L&I-DOSH, and the DOH. The topic was addressed during the most recent DOH Q&A webinar held on June 3, 2021. The slides can be found here.

It is very important for each assisted living and skilled nursing facility to understand the differences between conventional PPE use and contingency versus crisis standards. These different modes of PPE use can be found on the CDC website. As well, the American Health Care Association and National Center for Assisted Living (AHCA/NCAL) has provided a PPE Action Brief for facilities to utilize to take action to ensure compliance.

It is also important to maintain records of your facility’s burn rate (burn rate calculator) and to maintain adequate supplies of PPE to meet the staff and resident needs. It is recommended that each facility maintain a 90 day supply of PPE resources on hand as space allows. If a facility is not operating in conventional PPE mode, a facility may need to explain the rationale and provide evidence of PPE orders, supply chains utilized, and emergency requests for PPE to explain the non-availability of PPE to support conventional use to regulatory bodies (DSHS-RCS and L&I-DOSH). A failure to operate in conventional PPE mode could subject the provider to substantial penalties. For questions regarding the use of PPE, please reach out to the DOH-HAI Team.

Labor & Industries issued updated guidance related to the use of respirators and aerosol generating procedures on May 21, 2021. This update states the following:

The Department of Health (DOH) is in the process of working with L&I to update their current PPE guidance regarding the use of N95’s and the aerosol generating procedures, including but not limited to nebulizer/SVN treatments and the use of C-PAP/Bi-PAP machines. The draft guidance is in the process of being written and adopted in the DOH PPE guidance. Currently, the proposed draft guidance states the following:

Providing care that requires getting in the same rooms as ANY resident who is receiving a procedure or undergoing an activity for which respirators are required due to the generation of aerosols that pose a COVID-19 transmission hazard. This includes, but is not limited to, procedures identified by DOH, CDC, and the following: administering medicines with a nebulizer, spirometry, use of a BiPAP or C-PAP, deep or forced breathing exercises, or collecting or handling specimens from known or suspected COVID-19 patients. The door to the resident room should be closed during the procedure and for at least 3 hours following the procedure. Anyone entering the room within 3 hours following the procedure must wear a respirator. If a facility knows the ventilation and filtration rate of the room, it may use this table from CDC to determine the time a room should stay closed following the procedure. If the door needs to remain open, workers walking by the open door must remain at least 6 feet from the open door, unless wearing a respirator. 

It is anticipated that this guidance will be updated in the coming weeks. Keep in mind that this is draft, and the exact wording may change when released by the DOH. Also note that this guidance does not prohibit a resident from leaving the room for 3 hours using necessary precautions. This information is being sent out to you in anticipation of this guidance in order for you to review and ensure your policies and procedures are up to date, as well as staff training.

If you have questions regarding these issues, please reach out to the DOH-HAI team.

All skilled nursing facilities must ensure they are meeting the Centers for Medicare & Medicaid Services (CMS) published Interim Final Rule on COVID-19 Vaccine Requirements that was issued in May. This rule applies to residents, clients, and staff of all Skilled Nursing Facilities (SNF). CMS also published a QSO memo to state survey agencies on how to operationalize this new requirement. 

Your facility will need to input this information directly into NHSN via the COVID-19 Reporting Module by 11:59pm, Sunday, June 13 or CMS will issue the facility a citation and subsequent civil monetary penalties for every week the facility does not report as required. More information, training, and resources are available on the CDC website Weekly HCP & Resident COVID-19 Vaccination | LTCF | NHSN | CDC. If you have questions regarding NHSN, please reach out to Larissa Lewis or Paula Parsons at DOH. 

The American Health Care Association and the National Center for Assisted Living (AHCA/NCAL) is asking providers (SNF, AL, ID/DD) to complete a 15-minute survey to gauge how the industry is faring in 2021. Providers will be asked about several topics, including workforce, vaccines, personal protective equipment and finances. You may download a copy of the questionnaire if you wish to gather the necessary information before filling it out online. 

Your participation will help AHCA/NCAL address questions from policymakers and advocates for ongoing resources to the profession. Please complete the survey by the end of the day on Friday, June 11.  

Back in September 2020, CMS clarified that providers could utilize actual emergencies resulting in the activation of their emergency plan to offset the need for an annual full scale, community-based exercise. The COVID-19 Public Health Emergency that providers have been responding to and recovering from since March 2020 qualifies as such an emergency.  

CMS indicates that to meet Emergency Preparedness requirements, providers must be able to demonstrate their experience activating their emergency plans through written documentation. This is most commonly accomplished through an After-Action Report (AAR) and Improvement Plan. AHCA/NCAL has developed a COVID-19 AAR Template​ that members can utilize to document their response and recovery efforts during the pandemic. The template is developed in a nationally recognized format and simplifies the documentation process. It is fully editable.  

During your next survey, be prepared to provide a completed AAR and identify any revisions to the organization’s emergency plan as a result of the after-action review process. ​

The Washington Society of Post-Acute and Long Term Care Medicine is hosting a webinar on Wednesday, June 16, at 6 PM entitled Coping with COVID - Relief for Caregivers...Supporting Our Staff, Supporting Ourselves. This one-hour webinar will be informative, joined by Paige Hector, MSW, of the AMDA Behavioral and Mental Health Advisory Council, Dr. Jason Heffernan, and Linda Jahn, Board Members at WA-PALTC, and Dr. Sabine von Preyss-Friedman, WA-PALTC as moderator. Register here.

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.