Elevating the Post-Acute and
Long Term Care Profession

April 5, 2020


Value of cloth face coverings/masks. Yesterday Health Director Dr. Amy Acton recommended that members of the general public use homemade cloth face coverings when in places where they may have close encounters with others (e.g., grocery store). Her recommendations echo the Centers for Disease Control and Prevention (CDC). But that is for the general public. Previous guidance from Dr. Acton recommends universal masking for healthcare personnel and states, "[i]n settings where facemasks are not available, healthcare personnel (HCP) might use homemade masks (e.g., bandana, scarf) for care of patients with COVID-19 as a last resort. However, homemade masks are not considered PPE, since their capability to protect HCP is unknown. Caution should be exercised when considering this option. Homemade masks should ideally be used in combination with a face shield that covers the entire front (that extends to the chin or below) and sides of the face."

It is true that cloth face coverings are not PPE, and they do not adequately protect the wearer from potential infection. This is because the cloth can become saturated through exhalations and, by osmosis, usher droplets through the covering. A face shield would help reduce the likehood of droplets getting on the outside of the cloth.

The value of cloth face coverings in public and in healthcare is for source control. The most likely source of infection to patients is staff members unknowingly carrying it from the outside community. Cloth face coverings effectively contain droplets emitted by the person wearing the covering and thus are useful in a universal masking scenario in healthcare to preserve true PPE for care of people who are known or suspected to be infected.

Interpreting CMS blanket waivers. Last Monday, the Centers for Medicare and Medicaid Services (CMS) issued a series of blanket (national) waivers for Medicare and Medicaid requirements under section 1135 of the Social Security Act. Unfortunately, though, CMS described many of the waivers in a vague, summary fashion and only in a fact sheet, not in a more official CMS pronouncement. For instance, the waiver relating to Payroll-Based Journal (PBJ) reporting merely reads, "CMS is waiving 42 CFR 483.70(q) to provide relief to long-term care facilities on the requirements for submitting staffing data through the Payroll-Based Journal system." There is no explanation whether the relief is that providers simply can defer PBJ reporting beyond the normal deadline or whether they do not have to compile or report the PBJ data at all. AHCA is seeking further clarification from CMS of the waivers so providers know the true extent of the flexibility they provide.


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