COVID-19 UPDATE #150
April 1, 2021
REIMPLEMENTATION OF SURVEYS, INSPECTIONS, AND EVALUATIONS
In a Dear Administrator letter dated March 31, 2021, all providers are informed that Residential Care Services (RCS) is planning a gradual reimplementation of full surveys, inspections, and evaluations beginning in April. The process will be a hybrid using onsite and remote methods, and will combine the standard survey, inspection, or evaluation process with the focused infection prevention assessment process. The letter also states that providers with EHR "should" provide surveyors/inspectors with remote access to electronic health records.

The letter also explains that this reimplementation will be gradual, starting with small numbers of facilities and homes each month. Providers are encouraged to prepare for reimplementation by conducting mock surveys, inspections, or evaluations using the Standard Operating Procedure and the Focused Infection Prevention Assessment Tool specific to your setting. The letter contains links to past Dear Administrator letters with specific links.

When RCS staff arrive at your facility or home, you must allow them entrance as they are considered essential workers. (See this linked provider letter dated November 18, 2020, for more information.) As essential workers, RCS staff are not considered visitors and do not sign a visitor attestation, nor are they included in the calculation of maximum capacity. Policies that impose time limits or restrict hours do not apply to the RCS staff conducting surveys, inspections, or evaluations as these may interfere with the process. Providers are encouraged to reach out to their regional field managers with any questions.

It is anticipated that RCS will be holding webinars some time next week to discuss the reimplementation of full surveys/inspections with providers. As soon as more information is announced, WHCA will pass it on to you. As full surveys/inspections are reimplemented, please share concerns, questions, and outcomes of the process as they arise with Vicki McNealley or Elena Madrid.
DEAR ADMINISTRATOR LETTERS PROVIDE UPDATE TO SAFE START PLANS FOR AL AND SNF PROVIDERS
In a Dear Administrator letter to skilled nursing providers and a letter to assisted living providers dated March 29, 2021, providers are notified of updates to the Safe Start recommendations and requirements document. The letters address visitation, risk assessment and quarantine, facility operations, and other important reminders.

The letters also provide links to the updated Risk Assessment Template to assess COVID-19 exposure risk for residents after community visits and the updated Safe Start for Long-Term Care Recommendations and Requirements document - assisted living, skilled nursing - in its entirety. Providers are encouraged to email the RCS Policy Unit if they have questions.
EMERGENCY RULES SUSPENDING TB TESTING ARE EXTENDED
Effective March 12, 2021, the Occupational Safety and Health Administration (OSHA) announced a national emphasis program to focus on enforcement efforts related to COVID-19 hazardous conditions and has targeted the long term care sector under this directive. This directive provides L&I’s Division of Occupational Safety and Health (DOSH) program with the authority to walk into a facility and perform an inspection, solely on the basis of the program emphasis. Facilities should be prepared for an inspection from DOSH, and should take some time to review their current COVID-19 protocols, as they relate to worker safety. WHCA and ERNWest have received numerous reports from facilities around the state that are finding themselves subject to these inspections. Here is what we have learned:

What are DOSH inspectors specifically looking for?
Documentation for the following items:
  1. Respiratory Protection Program. A written copy of your program must be provided. EVERY facility should have this document in place, along with a system for fit testing. If you have employees in your facility that interact with any COVID positive residents, they MUST be protected with a tight-fitting (N95) type respirator. Any employee who must wear a tight fitting respirator must be fit-tested prior to donning their N95 mask. Make sure you’ve done everything possible to source appropriate PPE and have a fit testing kit on hand. Make sure to document these efforts and show inspectors proof if you’ve had difficulty obtaining these supplies in the past.
  2. Fit testing documentation and medical evaluation forms. For facilities that performed these procedures in-house, make sure you have the correct documentation. Medical evaluation forms should be filled out and signed by a licensed healthcare provider or registered nurse whose scope of practice allows for this type of evaluation. Inspectors may question the RN on their knowledge of respiratory hazards. Make sure your RN has the proper qualifications to perform the medical evaluation. 
  3. OSHA 300 logs for 2020 & 2021. Inspectors will access your OSHA 300 logs and will ask you for instances of infected staff and residents. If you fail to record a case as “work related,” you should expect to have these logs scrutinized. OSHA has guidance on their website on how to determine if a work-related exposure contributed to a positive COVID-19 case. 
  4. Program review. What does your written COVID-19 plan look like, and how do you plan to protect your workers in the event of an outbreak? What is your plan for distributing PPE to affected workers?
  5. Use of airborne isolation areas. Have you created a space for COVID-19 positive residents to be housed outside of the general facility areas? What does your isolation area look like? Employees should be trained and familiar with these protocols.
  6. Employee roster, to include names, title, shift worked, personal phone number and emails for the purpose of conducting employee interviews. Make sure to document when employees tested positive and/or showed COVID-19 symptoms.
  7. Job descriptions for caregivers.
  8. Picture of N95 respirators used. What are the brand and model numbers?
  9. Decontamination procedure for re-use of N95 respirators. 
  10. Type of hand sanitizer used in your facility.

To help answer any questions around these inspections, we are offering a free webinar on Tuesday, April 6, at 11:00 AM, presented by Shamus Harmon of ERNWest. Shamus will lead you through the OSHA inspection process, and will review the steps necessary for a successful respiratory protection program. Click here to register for the webinar.
DOH AND L&I PROVIDE NEW GUIDANCE ON PPE AND FIT TESTED RESPIRATORS
The Department of Health (DOH) and the Department of Labor and Industries (L&I) have released clarifying guidance on use of personal protective equipment, including fit-tested respirators, for long-term care facilities.

They are also providing these additional resources:

If you have questions, please contact hai-covid@doh.wa.gov or LNI at eyeonsafety@lni.wa.gov.
DOH PROVIDES VISITATION GUIDANCE DOCUMENTS FOR LTC FACILITIES
The Department of Health (DOH) is providing documents to assist long term care providers with visitation. The documents below can be utilized to help communicate visitation guidance and instructions.
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.