Today, your facility may or may not have a known or suspected case of COVID-19, but it is highly possible you will see one in the future. Healthcare facilities across the world are suffering as a result of the COVID-19 pandemic. This pandemic requires agility and flexibility to transform operations quickly and without warning. One moment your facility is caring for residents in the normal fashion and in the blink of an eye, all daily operations change because someone has been diagnosed with COVID-19. Additionally, there is so much information distributed daily that it can be difficult or nearly impossible to keep up. To help you keep up with the most recent information for long-term care facilities during this challenging time, here are two recent highlights impacting operations and some clarity regarding the guidance from CMS and the CDC.
1. On March 23, CMS issued a QSO memo detailing prioritization of survey activities and a new tool surveyors will use to conduct the Infection Control Focused Surveys called the COVID-19 Focused Survey for Nursing Homes. This tool, used by surveyors, can also be used by facility leaders as a checklist to ensure the facility has sound infection control processes in place related to COVID-19.
Under this QSO memo, surveys will include: Complaints and facility reported incidents (FRIs) that are triaged at the IJ level. A streamlined infection control review will be conducted during this survey regardless of the nature of the complaint being investigated. The second survey will be a Focused Infection Control Survey. Providers will be selected for this survey by the State Survey agency, the CDC, and the HHS Assistant Secretary for Preparedness and Response, and the Initial certification surveys will continue to be authorized with current guidance and prioritization.
The QSO memo stated:
We are disseminating the Infection Control survey developed by CMS and CDC so facilities can educate themselves on the latest practices and expectations. We expect facilities to use this new process, in conjunction with the latest guidance from CDC, to perform a voluntary self-assessment of their ability to prevent the transmission of COVID-19. This document may be requested by surveyors, if an onsite investigation takes place. Furthermore, we remind facilities that they are required to have a system of surveillance designed to identify possible communicable diseases or infections before they can spread to other persons in the facility, and when and to whom possible incidents of communicable disease or infections should be reported (42 CFR 483.80(a)(2)(i) and (ii)). CDC recommends that nursing homes notify their health department about residents with severe respiratory infection, or a cluster of respiratory illness (e.g., > or = 3 residents or HCP [Healthcare Professionals] with new-onset respiratory symptoms within 72 hours). Local and state reporting guidelines or requirements may vary.
2. On March 17, the CDC issued Strategies for Optimizing the Supply of PPE. They’ve provided a framework dividing capacity into three categories that are: conventional, contingency, and crisis. Select a category that fits your situation. This will depend on several things including your supply chain, surges you may experience, and individual resident cases of other infectious illnesses. For example, if you experience crisis capacity, the CDC recommends using face masks beyond the manufacture designated shelf life. There is guidance for implementation of limited re-use of face masks, and prioritization of use of face masks is given for various activities. This will allow your leadership team to plan accordingly for today, but also for what you may experiencing in the coming days. Look for opportunities to conserve PPE. Have very frank conversations with your staff about the use of PPE and discuss the safe ways to conserve.
In addition to using the CDC’s Guidance for Optimizing PPE, think about who in your community may have supplies they don’t need right now.
a. Schools who provide healthcare-related education may have supplies. This includes all disciplines, not just nursing schools.
b. Dental offices in your community might have closed temporarily and have face masks, goggles, and gloves.
c. Tattoo parlors use gloves and face masks, and many have been closed during the pandemic.
d. Hardware stores, such as Harbor Freight Tool who announced donations of gloves and masks, may have gloves and other PPE.
e. Speak to the hospital you have a referral partnership with. They want you to treat people in-house as much as possible right now to keep beds available in the hospitals for the sickest. Let them know about your supply of PPE and the capacity you’re functioning at. Hospitals are working with universities and private entities to use 3D printing and laser cutting technology to make PPE.
f. Contact your local health department. Working with them right now is of paramount importance. Let them know your supply of PPE and the capacity you’re functioning at. They are working with the state government to access emergency supplies of PPE.
For additional up-to-date information and tools to help you during this pandemic, please visit the AAPACN website dedicated to COVID-19 resources.