March 10, 2020
AHCA/NCAL guidance and related materials. Late yesterday afternoon, AHCA/NCAL issued its own guidance for skilled nursing facilities and assisted living (AL) communities. The guidance focuses mainly on people such as visitors entering the building and is more stringent than the Centers for Disease Control and Prevention (CDC) recommendations. Specifically, AHCA/NCAL encourages all SNFs and ALs to limit entry to an as-needed basis, in addition to screening people for respiratory infections and potential exposure to COVID-19. Clear, comprehensive, and frequent communication of these restrictions is critically important. In addition, AHCA/NCAL recommends requiring everyone who enters the building to clean their hands and placing handwashing stations or hand sanitizer at entrances. Another key aspect is avoiding gatherings within or outside of the center. Along with the guidelines, AHCA/NCAL provided a screening tool for visitors, template letters for families and staff, and talking points for member use. Although the AHCA/NCAL guidance is not specifically applicable to other congregate settings such as ICFs/IID or independent living, it nonetheless may be instructive. The key factor in the degree of precautions that should be taken is whether the people living in the setting are older or medically compromised.
Latest CMS guidance for SNFs. Shortly after the AHCA/NCAL guidance, the Centers for Medicare and Medicaid Services (CMS) came out with new guidance for SNFs that amends Quality, Safety, and Oversight (QSO) Letter 20-14-NH. Like AHCA/NCAL, CMS's primary thrust is limiting visitation. While more stringent than previous federal guidelines, the revised QSO is less aggressive than the association guidelines because it only calls for discouraging, versus limiting, visitors when there are no confirmed cases of COVID-19 in the county or adjoining counties. We recommend using the more protective AHCA/NCAL guidance. There are some other differences between the two resources, as outlined here. The CMS document further refines the screening criteria for prohibiting (versus limiting) entrance, suggests cohorting patients, and discusses the shortage of personal protective equipment (PPE). We suggest all members carefully review both the AHCA/NCAL and CMS materials.
Hospice guidance. CMS issued a specific QSO, 20-16-Hospice, that addresses both in-home and inpatient hospice care, presented in a question-and-answer format. The guidelines for inpatient care are similar to those for SNFs. The in-home guidelines address such issues as home isolation and PPE. CDC previously published guidance for home care, but it is not especially detailed.
Testing. On a call this afternoon with OHCA and other provider organizations, Health Department (ODH) Director Dr. Amy Acton discussed testing for COVID-19. She emphasized that testing should be ordered by a primary care physican based on careful analysis of each case and said hospitals can do the swabs needed to test. Currently the testing is done at the ODH laboratory, but Dr. Acton said there should be some private labs that can do it before long. CDC previously issued detailed guidelines on testing.