COVID-19 UPDATE #248
June 10, 2022
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REVIEW UPDATED CMS EMERGENCY PREPAREDNESS EXERCISE EXEMPTION MEMO RELEASED MAY 26 |
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On May 26, 2022, CMS again updated QSO-20-41. This update clarifies that providers are exempt from the 2021 and 2022 FSE so long as the facility is still operating under an activated emergency plan or has reactivated its plan due to COVID-19.
If you choose to utilize the exemption, you should ensure you document your organization's COVID-19 response in a formal After Action Report (AAR). If you have already completed a COVID-19 AAR in a previous year, you should consider updating the AAR to reflect ongoing response, lessons learned, and opportunities for improvement. AHCA/NCAL members can access a COVID-19 AAR Template on the website.
One key component to a comprehensive AAR is an Improvement Plan (IP). The IP should serve as a roadmap for future plan enhancements and training focus. Don't forget that documenting your organization's COVID-19 response will only address one of the two required annual exercises. To comply with CMS requirements, facilities must still conduct one of the following:
- Another full-scale exercise
- Individual-facility-based functional exercise
- Mock disaster drill
- A tabletop exercise or workshop
Read the full updated CMS QSO memo.
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CLARIFICATION OF IN-SERVICE TRAINING WAIVER REQUIREMENT TERMINATED JUNE 6, 2022 |
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The Centers for Medicare & Medicaid Services (CMS) has provided clarification on the In-Service Training requirements of §483.95(g)(1) for SNFs and NFs; this requires nursing assistants to receive at least 12 hours of in-service training annually. This waiver requirement was set to terminate on June 6, 2022.
The original waiver included language indicating the termination of the waiver would take place after the public health emergency (PHE) ends. The original language stated, “postponing the deadline for completing this requirement throughout the COVID-19 PHE until the end of the first full quarter after the declaration of the PHE concluded.”
However, CMS has terminated the waiver under different conditions and provided clarification that it will allow staff 12 months after the termination of the emergency waiver on June 6, 2022, to complete the required 12 hours of in-service training.
CMS is also planning to add this clarifying language to the document titled “COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers” located on the CMS Emergencies website. Please visit Coronavirus waivers & flexibilities for more information from CMS on waivers.
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DOH RELEASES VISITATION VIDEO |
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The Strategic Partners Program in the Healthcare-Associated Infections and Antimicrobial Resistance (HAIAR) section of the Washington State Department of Health (DOH), is pleased to announce the release of a webpage containing links to two educational videos to help visitors to long term care facilities learn about basic infection control measures for preventing COVID-19 and other infectious diseases. The long term care visitation video describes basic infection prevention practices, while the long term care isolation precautions video covers the proper use of personal protective equipment when visiting someone who is in quarantine. The site also includes an informational flyer containing a QR code that can be scanned to watch the videos. In addition, you will find corresponding guidance documents. Please print and share these resources with visitors to provide them with knowledge and tools to keep everyone safe.
The COVID-19 pandemic has taught us all many lessons about how to best protect vulnerable residents. One of those lessons is that everyone has a role in infection prevention, even visitors. Visiting someone in a long term care facility, including nursing homes, and veterans’ homes, is so important for both the resident and the visitor. However, it also poses a risk of bringing illness into the building, and infecting residents and staff, and that is why DOH produced the two videos.
The videos and several of the guidance documents are in the process of being translated and will be added to the webpage as they become available. If you require additional translation, please contact Kathy Silverman, Health Services Consultant. Questions and comments about the videos and webpage may be directed to Bonita Campo, Special Projects Unit Supervisor. |
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DEAR ADMINISTRATOR LETTER EXPLAINS ALTERNATIVES TO TEMPORARY BARRIERS USED TO SEPARATE COVID AREAS IN LTC SETTINGS |
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In a Dear Administrator letter dated June 10, 2022, information is shared to all providers about alternatives to temporary barriers used to separate COVID areas in long term care settings. Although these CMS waivers did not specifically apply to all long term care settings, use of the temporary barriers was also allowed in other settings to create a dedicated COVID area through use of state-based waivers or approvals. The CMS Blanket Waiver allowing temporary barriers expired June 7, 2022. Nursing facilities will no longer be able to utilize temporary barriers to designate a COVID area. This is considered a violation of the Life-Safety Code (LSC).
At this time, all other long term care providers are also asked to discontinue use of the temporary barriers to create a dedicated COVID area. Barriers do not equate to being infection-free or eliminating transmission risk. Providers must continue to implement actions to reduce the likelihood of COVID-19 transmission without the use of temporary barriers. The letter provides actions facilities can take to reduce COVID-19 transmission. The letter also provides the following information regarding regulatory response:
- Use of barriers (i.e., zippered walls) to separate COVID-19 units is a potential Life Safety Code (LSC) violation in nursing facilities. It is considered a concern for sprinkler systems in facilities required to install this type of fire safety system. If RCS staff see a barrier separating COVID from non-COVID areas in use, the surveyor/licensor will refer the facility to the State Fire Marshal.
- If the facility does not use a barrier to separate COVID-19 from non-COVID-19 units, this is not a violation. RCS staff will focus on clean to dirty process flow between units.
If you have questions, please email Katherine Ander. |
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STAY CURRENT ON RESIDENT AND STAFF COVID-19 VACCINATIONS |
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As cases of COVID-19 continue to rise throughout the country, it’s important that long term care facilities and communities encourage staff and residents to stay up to date on their vaccination status. The CDC defines up to date as having received all doses in the primary series and all boosters recommended, when eligible. Most recently, people over 50 are recommended to receive a second booster of either the Pfizer-BioNTech or Moderna COVID-19 vaccine at least four months after their first booster.
For skilled nursing facilities, staying current on COVID-19 vaccines is also important since various guidance from CMS hinges on resident or staff up to date status. This includes:
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Nursing Home Visitation Guidance (QSO-20-39-NH): Guidance and recommendations, such as the usage of source control masks and outdoor visitation, differs for those who are up to date on their vaccines.
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Nursing Home Testing Guidance (QSO-20-38-NH): Routine testing of staff is only required for those who are NOT up to date on their vaccines.
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Nursing Home COVID-19 Vaccination Requirements for Residents and Staff (QSO-21-19): In situations where the COVID-19 vaccine requires multiple doses, nursing facilities must offer and provide current information regarding those additional doses.
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AHCA/NCAL ENDORSES TRAVEL NURSING AGENCY TRANSPARENCY STUDY ACT |
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This week, U.S. Senator Kevin Cramer (R-ND) introduced the Travel Nursing Agency Transparency Study Act. This legislation, which the American Health Care Association and National Center for Assisted Living (AHCA/NCAL) endorses, requires the Government Accountability Office to conduct a study and report to Congress on the business practices and the effects of hiring agencies across the health care industry during the COVID-19 pandemic. Senator Cramer noted in his press statement on the bill introduction that:
“The health care industry was already experiencing a shortage of professionals prior to the pandemic, but COVID-19 exacerbated this issue throughout the country, especially in rural communities. Travel nurses were employed to help meet the rising demands. Over the past few years, there have been anecdotal reports of hiring agencies inflating prices and monopolizing the nursing workforce, potentially leading to a number of concerning consequences for providers, patients, and taxpayers, including inflated prices for care, further nursing shortages, and continued strain on the entire health care system.”
The full bill is accessible here.
AHCA/NCAL has heard from members across the country that nursing and direct care staffing agencies are charging exorbitant prices to health care facilities that need workers. These agencies are charging more than double and, in some cases, as much as quadruple pre-pandemic rates. AHCA/NCAL has done extensive outreach and been very vocal on the Hill and to the Administration on this matter and the negative impact it is having in long term care.
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TACOMA PIERCE COUNTY HEALTH PROVIDES UPDATE FOR PROVIDERS |
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The Tacoma Pierce County Health Department has provided an update for long term care providers in Pierce County. The publication includes information on testing, vaccines, infection control, and much more. There is also information on resources, state, and local guidance for long term care facilities and homes. Providers may email questions to longtermcare@tpchd.org.
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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.
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