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June 30, 2020


Quarantining new admissions. One section of the Centers for Disease Control and Prevention (CDC) guideline, "Preparing for COVID-19 in Nursing Homes, as updated June 25, covers new admissions to SNFs. While not specifically applicable to other facility-based settings, the guidance reflects CDC's current thinking and may be instructive. This section of the guideline directs:

Create a Plan for Managing New Admissions and Readmissions Whose COVID-19 Status is Unknown.

  • Depending on the prevalence of COVID-19 in the community, this might include placing the resident in a single-person room or in a separate observation area so the resident can be monitored for evidence of COVID-19. HCP should wear an N95 or higher-level respirator (or facemask if a respirator is not available), eye protection (i.e., goggles or a disposable face shield that covers the front and sides of the face), gloves, and gown when caring for these residents. Residents can be transferred out of the observation area to the main facility if they remain afebrile and without symptoms for 14 days after their admission. Testing at the end of this period can be considered to increase certainty that the resident is not infected.

Read literally, this guidance calls for quarantining all new admissions whose COVID-19 status is unknown in single rooms, with staff using full personal protective equipment (PPE), for 14 days after admission. Two key undefined terms are when COVID-19 status is considered unknown and the degree of prevalence of COVID-19 in the community that requires quarantining. In Ohio, the Department of Health's (ODH's) Bureau of Infectious Disease (BID) interprets unknown as meaning anyone who is not known to be positive. As a result, any new admission who either has not been tested or tests negative before admission, no matter how many times, is subject to the quarantine requirements of the CDC guideline. BID also has not identified any level of prevalence in the community below which quarantine is not required.

Re-opening heightens importance of source control. As more Ohioans take advantage of society re-opening and in many cases ignore precautions, COVID-19 cases in the community have risen dramatically. Unfortunately, people working in and visiting health care facilities are not immune from these societal trends. It is likely more COVID-19 is entering buildings, particularly in communities where it is prevalent in the general population. This makes effective source control all the more important. Source control - primarily universal masking and scrupulous hand hygeine - likely is the reason why the number of cases in Ohio facilities has dropped so much over the past month, despite the general prevalence remaining relatively constant until the past week. It will be critical going forward to ensure that all staff rigorously and properly employ source control, whether or not they personally agree with it. The risk to the vulnerable people they serve is simply too great.

Senate passes House liability bill. The Senate, by a 22-6 vote, passed House Bill (HB) 606, the House of Representatives' version of COVID-19 liability protection legislation for health care and other businesses. The Senate-passed bill, however, picked up several amendments in the Judiciary Committee that could lead to a conference committee later this summer. While HB 606 as passed by the Senate retained the emergency clause inserted by the House, the Senate stripped out one key provision important for Democratic support for the emergency in the House. This provision, which establishes a presumption that COVID-19 cases among workers in certain industries are workplace-related, does not affect health care, but is opposed by several significant business groups. If the emergency clause cannot be sustained in conference committee, the bill would not take effect until 90 days after signature by the Governor. The ultimate fate of this legislation is unclear at this time.

Accrediting Organizations resume surveys. Today, ODH confirmed that Accrediting Organizations (AOs) have resumed surveys in Ohio. After further conversations with CMS, ODH determined that the AOs themselves would determine when it was time for them to re-enter states. This interpretation conflicts with CMS Quality, Safety, and Oversight letter 20-31-All, published on June 1, which specifies that states would authorize survey resumption. The AOs indicate that providers can expect a recertification visit or focus visit associated with a previous site visit. Site visits for deemed organizations remain unannounced. Initial site visits will continue to be scheduled based on readiness. Providers should expect assessment of compliance standards to acknowledge current federal blanket waivers, state Medicaid waivers, and applicable state executive orders

ICF cost report audits to resume. The Departments of Developmental Disabilities and Medicaid shared today that the Auditor of State’s review of ICF-IID cost reports will resume soon. The plan is for the reviews to be performed remotely to help ensure the safety of ICF residents. 

Latest pop-up testing sites. Please see this page for a list of pop-up testing sites operating this week. These sites offer free COVID-19 testing for all comers and may be an option for providers needing to get staff tested.

Update on hospice in HCICs. Responding to an inquiry from OHCA about reimbursement for residents in a Health Care Isolation Center (HCIC) who elect hospice, the Department of Medicaid’s Julie Evers said they currently are reviewing the billing and regulatory considerations for those circumstances, as well as system configurations required for room and board payment. We will update members when we have more concrete information and instructions on this topic.

Roommates must socially distance in dining room, activities. OHCA advocated for allowing roommates in facilities to be able to eat and to attend activities together without strict social distancing. OHCA argued that roommates are not socially distanced in their rooms and that they share a toilet room. They are similar to families outside facilities who eat together and share activities. ODH staff replied that this is against the CDC recommendations and that allowing it would leave facilities at risk for citation. OHCA will continue to advocate for reasonable, safe measures to ensure residents are afforded independence and autonomy within their congregate living environments.

ODH infection control complaints. One of the triggers for additional Focused Infection Control Surveys is infection control-related complaints. ODH staff today listed some of the common infection control complaints they receive. Complaints from families mostly pertain to staff not appropriately wearing personal protective equipment and facilities commingling residents. Per ODH, families also report a lack of information provided by facilities as well as difficulty reaching staff. ODH also reported that they receive complaints from staff members who do not understand the applicable guidelines. They suggested increased education and resources for staff members on the guidelines potentially would reduce these complaints.