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December 1, 2020


Latest COVID-19 Vaccine Developments. Today, the Centers for Disease Control and Prevention's Advisory Committee on Immunization Practices (ACIP) recommended that both long-term care residents and health care personnel be included in Phase 1a of the COVID-19 vaccine distribution. Previously, only health care workers were in Phase 1a. This recommendation is intended to guide allocation of vaccines by the federal and state governments. ACIP defined the two groups as follows:

Health care personnel are defined as paid and unpaid persons serving in health care settings who have the potential for direct or indirect exposure to patients or infectious materials

Long-term care facility residents are defined as adults who reside in facilities that provide a variety of services, including medical and personal care, to persons who are unable to live independently

If further sub-prioritization is needed because of inadequate supply of vaccine, the committee recommended among staff, individuals with direct patient contact and unable to telework, personnel working in residential care or long-term care facilities, and personnel without known infection in prior 90 days. Among residents, SNF patients were recommended for sub-prioritization.

Meanwhile, Governor Mike DeWine's Office issued a release discussing the state's preparations to receive and distribution vaccines. The release reported the Health Department yesterday participated in a nationwide exercise modeling packaging the Pfizer vaccine, which requires cold-chain management. The wording on vaccine distribution after the state receives it was both specific in some areas and vague in others:

  • The Pfizer vaccine will be shipped directly to Ohio’s 10 prepositioned hospital sites. As vaccine supply increases, additional providers will receive direct shipments if ordering 975 doses or more of the vaccine.
  • Providers requiring fewer than 975 doses, such as smaller local health departments and physician’s offices, will not receive a direct shipment from Pfizer. In these cases, Pfizer will ship the vaccine to the ODH RSS warehouse, where the vaccine will be redistributed in increments of 100.

There is no mention of long-term services and supports in the release, and it does not detail how vaccines shipped to the pre-positioned sites will be disseminated from there. The release does mention, "[u]pon granting of an emergency use authorization, it is anticipated that the Moderna vaccine will be shipped directly to providers administering the vaccine and will not be processed by ODH at the RSS warehouse."

Speaking of the Moderna vaccine, the company applied to the Food and Drug Administration (FDA) for an Emergency Use Authorization (EUA) yesterday. Moderna expects its application to be considered by the Vaccines and Related Biological Products Advisory Committee, an FDA advisory group, on December 17, a week after its consideration of Pfizer's application.

DODD Supplying N95 Respirators to ICFs. In another move to support Ohio's ICFs/IID during the ongoing pandemic, the Department of Developmental Disabilities (DODD) announced that it ordered nearly 200,000 3M National Institute for Occupational Safety and Health (NIOSH) approved N95 respirators for distribution to ICFs. The department expects to receive the N95s very soon. DODD will ship the masks directly, free of charge, to ICF agencies based on an allocation methodology similar to allocation of the BinaxNOW tests. ICFs still will need to comply with the Occupational Safety and Health Administration (OSHA) respiratory protection standards (respiratory program, medical evaluations, and fit testing) for staff using the N95 masks. Please see the DODD announcement for more information.

Enhance Virtual Visits as Winter Moves In. Today's snowy conditions underscore the need for facility-based providers to do everything possible to expand virtual visitation and to communicate those opportunities to residents and families. The vast majority of SNFs in Ohio are precluded from offering indoor visits, either because of Centers for Medicare and Medicaid Services (CMS) red county status or because of an outbreak at the center. Likewise, most assisted living communities have halted visitation because of COVID-19 prevalence in the community or outbreaks. Outdoor visitation is no longer possible with the wintry conditions, which leave even window visits challenging. The only remaining option to offer needed contact with family members is virtual visitation. We recommend all members refresh their processes for virtual visitation and look for ways to enhance them. The top concern that members of the legislature, the DeWine Administration, and the media report hearing from constituents about facilities is inability to visit their loved ones. While certainly not the same as in-person visits, virtual visits at least offer some ability for connection. Consider thoughtful communication with families about the options you offer and how they can avail themselves of them, together with explaining why in-person visitation cannot be allowed at this time.

SNF Testing Opt-In/Opt-Out Survey Open Again. The Department of Aging's Nursing Facility COVID-19 Testing Opt-In/Opt-Out Survey is open now through Sunday, December 6, 2020, for the December 21, 2020, through January 15, 2021, testing cycle. Facilities that previously completed this survey only need to fill it out again if they wish to make changes to their current testing option. If no changes are needed, you are not required to complete the survey.  

Latest CMS County Positivity Ratings. CMS published its latest positivity rating color chart today for purposes of SNF testing frequency and visitation. The new table shows no green counties, 17 yellow counties, and 71 red counties, the highest number ever. Please check where your county stands. We recommend selecting (and documenting) a day of the week when you implement any changes you need to make in your testing frequency.

Pharmacy Board Requirements for COVID-19 Vaccine Administration. The Board of Pharmacy (BOP) informed OHCA that to administer COVID-19 vaccine, a facility that BOP terms "institutional" requires a Limited Category 2 Terminal Distributor of Dangerous Drugs (TDDD) license. A license limited to medical gases is not sufficient. This category of facilities includes SNFs and ICFs/IID. For congregate settings that do not currently have TDDD licenses and are not considered institutional (BOP refers to assisted living in this category), the board offers a First Aid Department license that can allow administration of vaccine. See this fact sheet for more information about these and other options for vaccine administration under BOP rules.