May 12, 2021
Governor to Cancel Health Orders - Except LTC. Governor
Mike DeWine, facing the threat of legislative action to rescind all
COVID-19 health orders on June 23, announced that he plans to have the
Health Department (ODH) cancel them earlier, on June 2, except for
orders affecting SNFs and assisted living communities or relating to
data collection. The Governor pointed to the impact of the COVID-19
vaccines, including now for children aged 12-15, and the decline in
cases to 123 per 100,000 (which nonetheless remains well about the
previously-set goal of 50). He also called out much lower
hospitalization rates and steep reductions in SNF cases: "While at one time, we had over 2,800 new cases per week in our nursing homes, today we are averaging less than 200 per week." Despite
these numbers, apparently the rationale for leaving the long-term care
orders in place is the existence of similar federal guidelines, although
the state orders are more stringent than the federal requirements. The
Governor's Office release states, "[m]easures being removed will
include facial covering protocols, social distancing guidelines, and
capacity restrictions for indoor and outdoor events."
Governor
DeWine also announced that the state will award 5 college scholarships
to children aged 12-17 and 5 prizes of $1 million to others who take the
vaccine. The state will give out the prizes each Wednesday starting May
26.
Vaccination Reporting to NHSN.
A useful primer on reporting vaccination data to the National
Healthcare Safety Network (NHSN), as required for SNFs by yesterday's
Centers for Medicare and Medicaid Services (CMS) interim final rule with comment period, is NHSN's frequently-asked questions
document (FAQ) on this topic. Although written before the rule came
out, the FAQ addresses a number of issues and provides links to other
resources such as data-tracking worksheets. The reporting requirement
takes effect June 13. Given that most facilities were not reporting
voluntarily to the vaccination module that opened months before the
mandate, a key question is whether retroactive entries are required. Our
reading of the FAQ is that facilities should start reporting by
providing the cumulative data for their current residents and staff as
of when the facility starts to report (e.g., June 13). The goal of the
reporting requirement is to allow CMS to publish current,
facility-specific vaccination rates. Entering past data, especially for
residents or staff who are no longer present, would not further that
goal. We have asked for clarification on this point, however, so please
stay tuned for any additional guidance we receive.
Guidance from BID. ODH's
Rebecca Sandholdt forwarded responses to two questions from Amanda
Smith of the Bureau of Infectious Diseases (BID). The following is the
verbatim text of the questions and answers.
Q 1. In a shared 2-bedroom apartment with 2
residents, if one is fully vaccinated and one is not vaccinated, what are
the expectations within the apartment in regards to masks for the 2
residents? We are aware that the unvaccinated resident would need to wear
a mask at all times when in common areas, dining and activities.
A 1. A 2 bedroom assisted living apartment is more
like a household setting. It would be reasonable to consider the shared
apartment as the personal living space (“room”), and expect masking when outside
of this shared personal living space (understanding of course that additional IPC measures would be needed if a resident was
suspected to have SARS-CoV-2 infection, as you indicated below) but not when
the residents are within the room.
CDC’s guidance, Interim Infection Prevention and Control Recommendations to
Prevent SARS-CoV-2 Spread in Nursing Homes,
is specific for nursing homes, including skilled nursing facilities, but may
also apply to other long-term care and residential settings such as assisted
living facilities. Please see the relevant excerpt below on use of source
control by residents.
Residents,
if tolerated, should wear a well-fitting form of source control upon arrival
and throughout their stay in the facility. Residents may remove their source control when in their
rooms but should put it back on when around others (e.g., HCP or
visitors enter the room) and whenever they leave their room, including when in
common areas or when outside of the facility. More information on options to improve fit is available from
CDC.
- Source control should not be placed on
anyone who cannot wear a mask safely, such as someone who has a disability or
an underlying medical condition that precludes wearing a mask or who has
trouble breathing, or anyone who is unconscious, incapacitated, or otherwise
unable to remove the mask without assistance.
Q
2. Is ODH in alignment with CDC and CMS in that all staff in a county
that is yellow or red do not have to wear eye protection but only the staff
providing patient care. Eye protection would also of course be worn in a
quarantine or isolation unit.
A 2. Based on the recommendations from CDC, ODH
recommends eye protection in patient
care areas if the facility is in a community with moderate to sustained
spread.
Per CDC:
“The Interim Infection Prevention and Control Recommendations to Prevent
SARS-CoV-2 Spread in Nursing Homes (https://www.cdc.gov/coronavirus/2019-ncov/hcp/long-term-care.html#healthcare-personnel)
states that for areas with moderate to substantial community transmission “Eye
protection should be worn during patient care encounters to ensure the eyes are
also protected from exposure to respiratory secretions.” If in a facility where
there is opportunity for staff to have spontaneous interaction with residents
who may require assistance while in the hall or common areas that would not
allow staff the opportunity put on eye protection before the interaction, it is
certainly reasonable to have staff wear eye protection when they are in areas where these encounters with
residents could potentially occur.”