Elevating the Post-Acute and
Long Term Care Profession

June 22, 2021

Aging Holds First Two Webinars. Today the Department of Aging (ODA) held webinars on a variety of topics for assisted living communities and later for SNFs. Repeats are scheduled for tomorrow. There was little new information. ODA pointed out that the visitation orders were rescinded last Friday, but did not address many questions about what the rescission means in practical terms. See our frequently-asked questions below, where we try to substitute for the lack of answers from the state.

ODA used a panel of medical directors to defend the state's decision not to follow federal guidance on testing unvaccinated staff, but to continue requiring twice-weekly tests. Director of Aging Ursel McElroy announced that effective June 28, the state will combine the portals for state-supported testing and maintenance vaccination. Only one login will be required per facility, useable by multiple staff, and providers can update their profiles and their testing and vaccination selections anytime. Rebecca Sandholdt of the Health Department said they do not know which providers reach out to the Regional Rapid Response Assistance Program (R3AP) and will not retaliate against facilities for doing so.

Disabilities Vaccination Toolkit Added. Last week, we reported that the Centers for Medicare and Medicaid Services (CMS) published a number of toolkits to assist in educating various populations about vaccination. Missing was a toolkit for people with disabilities. After OHCA inquired, CMS now has a disabilities toolkit.

Frequently-Asked Questions About Visitation. In the absence of a robust question-and-answer session on visitation during the state webinars, we offer some frequently-asked questions we receive from members.

Q. Are we required to open up visitation? Are there no restrictions?

A. Yes, you must allow visitation, including indoor, unless there is a current outbreak in the facility. There are special provisions for outbreaks. Otherwise, you can establish reasonable rules as necessary to ensure infection control (discussed below), but this does not mean prohibiting visitation. You always must allow compassionate care visitation.

Q. Are masks still required if the person is vaccinated?

A. Yes, visitors still must wear facemasks except if they are fully vaccinated, the resident is fully vaccinated, and they are alone in a private space. The same is true for residents during visits, although compliance may be difficult to ensure. Staff must continue to wear masks (and more personal protective equipment under some circumstances) except when in a gathering with other staff members, all of whom are fully vaccinated, or alone in a private space.

Q. Can visits be held in a semi-private room with the roommate present?

A. Centers for Disease Control and Prevention (CDC) and CMS guidance advises against this unless it is not possible for the resident to move to another location or for the roommate to leave the room temporarily. If everyone present is fully vaccinated, however, and the resident and the roommate prefer to stay in the room, we feel allowing them to do so creates very little risk.

Q. Can we establish visitation hours and limit the amount of time for visits?

A. Yes, but you should have an infection control-related reason for doing so that is documented in your policy, such as lack of staff to manage visits. The limitations should be reasonable, should allow for exceptions, and should not apply to compassionate care visits.

Q. Are we required to schedule visits?

A. No, that was a provision of the orders that were rescinded last Friday. You can have open visitation, but the infection control requirements such as screening visitors still apply under the federal guidelines. Another infection control consideration that may weigh in favor of scheduling visitations relates to the semi-private room situation. Open visitation could lead to both roommates' families arriving to visit at the same or overlapping times.

Q. Can visitors self-screen?

A. Yes, but the facility is responsible for ensuring that they are screened - that is, monitoring self-screening.

Q. Are we still required to keep a visitor log?

A. That too was part of the rescinded orders, but you need to have documentation that visitors are screened. This would not have to be a log, but could be completed screening forms, for example.

Q. Do we still have to keep up the ODA visitation dashboard?

A. No, this was an item in the rescinded orders. ODA may prefer that facilities continue to update the dashboard, but this may not be practical, for instance for open visitation.

Q. Are we required to limit the number of visitors? What about the age?

A. No, neither of these are required, although infection control considerations could lead you to adopt restrictions in your policy. Outdoor visitation is generally preferred under the federal guidance, and this might be particularly useful in the case of a larger group or children.

Q. Do we still need to escort visitors to the location of the visit?

A. No, this was yet another provision of the state order. You still should make a good-faith effort to ensure visitors follow infection control precautions, but that could be done by providing instructions.

Q. Can we ask if a visitor has been vaccinated? How do we make sure they are telling the truth?

A. Yes, because visitors have more freedom if they and the resident have been vaccinated (e.g., removing masks in the resident's room or other private space if all visitors and the resident are fully vaccinated). Visitors can choose not to answer, and if they don't, they should be treated as unvaccinated. There are no requirements for verifying vaccination status.

Q. Can we open more entrances for visitors, staff, others?

A. Yes, but everyone who enters the building still must be screened. You will need to make sure you have enough staff to supervise screening at multiple entrances.

Q. Do we need to monitor visits?

A. No, this is not required. For indoor visits, especially in-room, monitoring would be intrusive and would prevent vaccinated visitors and residents from being able to remove their masks.