Wednesday, April 29, 2020

New COVID-19 Resources & Important Reminders

Preparing for Widespread Testing 

The Centers for Medicare and Medicaid Services (CMS) has recently emphasized the importance of testing for COVID-19 in nursing facilities. In addition, a growing number of states are requiring testing of all residents and/or staff. When accessing testing, we recommend providers ensure that the tests are FDA approved PCR tests (versus Antibody/Serology tests) and that the lab will bill Medicare directly. Providers need to have a plan in place to isolate residents who test positive, and follow CDC guidance for staff that test positive. More information and guidance on preparing for widespread testing is available in here.


Continuing Restrictions on Visitors in LTC 

Even as states are beginning to lift their stay at home orders, nursing homes must continue to maintain current restrictions on visitors. As a reminder, CMS released guidance on March 13 that required all nursing homes to significantly restrict visitors and nonessential personnel, as well as restrict communal activities. The guidance indicates that individuals other than essential health care staff and visits for end-of-life situations, should no longer enter nursing homes until further notice.
Even though certain states may be lifting their individual stay-at-home orders, nursing homes must continue to follow this directive from CMS until new guidance is received. For help communicating these policies, please see our sample letter to families on restricting visitors.

Assisted living communities must follow any applicable state guidance. If no state guidance is issued, we recommend they follow AHCA/NCAL guidance and continue restricting the number of people entering the facility.

For all long term care communities, these restrictions remain critical safeguards to help protect against the spread of COVID-19.


Documentation & Asking for Help

Law firm Husch Blackwell lays out some general steps for documenting activities and response efforts to be prepared for surveys and potential litigation. AHCA/NCAL also recommends working with your legal counsel to develop practices. This resource is available to AHCA/NCAL members (log in required).

As a reminder, the association has developed brief guidance for facilities facing personal protective equipment and staffing shortages, as well as other challenges in receiving assistance. Most long term care providers do not have access to the adequate supplies or staff to provide the level of care needed to contain the virus. Documenting requests for assistance is a critical part of managing of the long term consequences of the lack of supplies and testing – and preparing for future surveys.

Unfortunately, also due to this crisis, many long term care providers are unable to fulfill requests for help made to regular contacts (e.g., suppliers, morgues, staffing agencies, etc.) and through traditional communication channels. Long term care providers need to regularly call for help and need to document these calls were made. Continue to reach out to these entities:

Be sure to check out the AHCA/NCAL guidance, which also has information on how to properly document calls for help and the importance of requesting a facility level waiver.


AHCA/NCAL Grant & Loan Management Resource Guide 

To aid members with managing the array of federal grants and loans, AHCA/NCAL has developed a basic primer (login required) for organizing oversight and day-to-day management of these emergency resources. The guidance includes federal cost reporting guidelines as well as recommended financial management approaches for members. This document is the Association’s first version; updates will be developed as the federal government and states release new or updated guidance.


COVID-19 Related Loss and Cost Calculator 

Also, available exclusively to AHCA/NCAL members is a COVID-Related Loss and Cost Calculator (login required). The purpose of this excel workbook is to offer a basic tool for members to assess allowable costs already reimbursed by pre-COVID payers, such as Medicare and Medicaid, and compare such reimbursement to shortfalls where grants and loans fill funding gaps. This tool will be particularly useful with reporting on and documenting use of the CARES Act Provider Relief Fund grants.


Scammers Posing as Government Officials 

AHCA/NCAL has developed a resource to warn providers about potential scammers posing as government officials. Learn more about how to screen callers claiming to be representing a state or federal agency or official or claiming to be from the IRS, Department of Commerce, or a Bank or other financial institution without first verifying the caller’s identity. This resource also includes ways to protect residents from scammers and some safety tips to confirm legitimate outreach calls from CMS or the CDC.

Separately, AHCA/NCAL had previously created a resource on how to beware of scams when working with vendors offering personal protective equipment.

Additional $75 Billion Added to the Provider Relief Fund

Last week, Congress approved and the President signed the Paycheck Protection Program and Health Care Enhancement Act. The bill provides:
  • $75 billion for health care providers to support the need for COVID-19 related expenses and lost revenue. This funding is in addition to the initial $100 billion provided in the Provider Relief Fund as part of the CARES Act, bringing the fund total to $175 billion.
  • $25 billion for COVID-19 testing
  • $321 billion increase in the Small Business Administration’s Payment Protection Program (PPP) loan to allow for more small businesses to apply to receive aid.
All of the provisions above are in addition to the provisions that are in the CARES Act, that was signed into law by the President last month.

See our summary of various legislation passed by Congress and how it impacts long term care.

Wednesday, April 22, 2020

Long Term Care Professionals Honored During Careers in Aging Week

AHCA/NCAL has partnered with the Gerontological Society of America, LeadingAge, and Argentum to celebrate Careers in Aging Week, April 19-25. AHCA/NCAL is taking this week to highlight the honorable work being done in the long term care profession during the COVID-19 pandemic.

“There has never been a time like this,” said AHCA/NCAL President & CEO Mark Parkinson. “Millions of people living in America’s skilled nursing centers and assisted living communities depend on our providers every day for vital care. There are so many amazing stories of dedication, sacrifice, and compassion by long term care professionals who are going above and beyond to ensure the safety, health, and happiness of our residents during this unprecedented time. These individuals are saving lives; they are heroes.”

Watch Mark's video to frontline caregivers and read the full press release here. Contribute to the conversation on social media throughout this week using #CareersInAging and tell us how you’re celebrating. And don’t forget to follow AHCA/NCAL on Twitter and Facebook to find resources, stories, and more.

New COVID-19 Resources

Where to Turn for Help  
AHCA/NCAL has developed brief guidance for facilities facing PPE and staffing shortages, as well as other challenges in receiving assistance. It is critically important that you raise the alarm and you document your efforts to obtain support.

Communication Strategies for Keeping Families Up to Date  
Effective communication is always important but is critical in this COVID-19 environment with heightened emotions, fear of the unknown, and restrictions on family member in-person visitation. Family members want to know that their loved one is safe, that providers are doing everything possible to protect their loved ones, and to feel a sense of connectedness especially because they can’t be with their loved ones. 

AHCA/NCAL has developed some potential tactics and strategies to keep family members and loved ones up to date.

Updated: Steps to Limit COVID-19 Spread and Outbreaks in Long Term Care
COVID-19 spreads principally person-to-person, and often is spread by asymptomatic individuals who do not realize they are sick. Every interaction between people increases the risk of spread. This includes staff to staff, staff to resident and resident to resident. It’s a simple formula for how spread happens – the more interactions that happen with a variety of people, the greater the likelihood of spread. 

AHCA/NCAL has updated our resource on action steps to take and continually reinforce to limit the spread of COVID-19 with all staff and residents. 

Resource for Staff to Embrace Social Distancing  
The actions of frontline staff in and outside long term care facilities can make an impact in mitigating the spread of COVID-19. Staff can also be strong ambassadors for best practices when in the surrounding community. It is important to arm your staff with knowledge they can implement at work and home as well as share with their own family and friends. 

AHCA/NCAL has drafted a template message for frontline staff on social distancing both while in and outside the facility. This document is intended to be distributed to or posted for frontline staff, to empower and encourage them to maintain social distancing and good hygiene. Tailor this message as needed, including any specific program(s) you are offering to staff members to make social distancing easier, such as assistance with acquiring groceries, offering transportation, etc.

Nebulizing Guidance  
AHCA/NCAL has developed new guidance that outlines when and what to do with COVID-19 residents with severe respiratory symptoms who need nebulizer treatments. CDC considers nebulizer treatments to be an aerosol generating procedure. This may increase risk of infection due to aerosols generated by the procedure or due to increased contact between health care providers and patients. Facilities should review the guidance and consider whether they can care for a resident who requires nebulizer treatment.

Hilton, American Express, and Marriott Provide Support Amid COVID-19

Hilton’s Rooms Donation Program to Frontline Medical Workers 
Hilton and American Express have partnered to donate up to one million free hotel nights to our association and other frontline medical professionals, so you can have a safe and welcoming place to stay as you support those impacted by COVID-19.

Bookings can be made for up to 7 consecutive nights at a time and are currently open through May 9th. The program will run through May 31st with rooms being added through the end of May on a rolling basis, subject to availability.

To search available hotels and book, log in on AHCA/NCAL’s website, and go to www.ahcancal.org/Hilton-Partnership to find a link to the program. Hilton has required that participating associations limit the offer to members to help ensure that the offer gets to who it was intended to reach – frontline health care workers treating COVID-19.

Marriott Community Caregivers Rate
Marriott is offering a “Community Caregivers Rate” to expedite the booking process for healthcare and relief professionals and support staff. This rate will be available from March 26, 2020 through June 30, 2020 at participating hotels.

Having trouble logging into our website? Go to our Member Dashboard forassistance. Please email COVID19@ahca.org for additional questions, or visit ahcancal.org/coronavirus for more information.

CMS Memo on Reporting Confirmed Cases

Late Sunday, CMS announced that it will be releasing new requirements for reporting and notification of confirmed COVID-19 among residents and staff.

CMS will be issuing these requirements through rulemaking in the coming days. These requirements will go into effect once the rule is issued. We don’t know at this time whether CMS will accept public comments upon issuance of the rule.

These new requirements will update previous notification guidelines shared by AHCA/NCAL for confirmed COVID-19 cases. We will share revised guidance and support materials once the regulations are released.

The announcement by CMS late Sunday applies only to nursing homes, so assisted living communities and facilities that serve the ID/DD population should continue to follow AHCA/NCAL’s guidance on notifications.

Notification of Confirmed or Suspected COVID-19
CMS and CDC will soon issue direction on standard formatting and frequency for all providers to report this information through the CDC’s National Health Safety Network (NHSN) system. CMS states this information will be used to support local and national surveillance, monitor trends in infection rates, and inform public health policies and actions. The information may be publicly
reported.

Current CDC guidance specifies that nursing homes notify State or Local health department about residents or staff with suspected or confirmed COVID19, residents with severe respiratory infection resulting in hospitalization or death, or 3 or more residents or staff with new-onset respiratory symptoms within 72 hours of each other.

Notifying Residents and their Representatives 
In addition, CMS will also issue through rulemaking new requirements to notify residents and their representatives to provide updates on new cases of COVID-19, new suspected cases, and facility actions and responses.

Specifically, nursing homes will be required to inform residents and their
representatives within 12 hours of:

  1. The occurrence of a single confirmed infection of COVID-19, or
  2. The occurrence of three or more residents or staff with new onset of respiratory symptoms that occur within 72 hours.
Regardless of whether there are new confirmed infections or three or more residents or staff with new onset of symptoms in 72 hours, nursing homes will have to provide updates on the facility’s status to residents and their representatives at least weekly.

These notices must include information on mitigating actions implemented to prevent or reduce the risk of transmission, including any changes to facility operations.

The memo states this information must be reported in accordance with existing privacy regulations and statute, and we are requesting clarification on how this will be operationalized given these new notification requirements.

For compliance purposes, it is essential that providers keep records of notifications that have been made.

Additional Requirements
The memo states that failures to report confirmed or suspected cases or failure to provide required notifications to residents and representatives, could result in an enforcement action by CMS.

CMS reminds providers of the requirements to permit access to nursing home residents and representatives by any representative of the Secretary or the State, in accordance with regulatory requirements at §483.10(f) (4)(i)(A) and (B). CMS indicates CDC may conduct additional on-site infectious disease surveillance, testing of healthcare personnel and residents, or other related
activities, as permitted under law. We will provide further information on this as soon as it is available.

These requirements will go into effect once rulemaking is issued.

Questions for CMS should be addressed to DNH_TriageTeam@cms.hhs.gov.

CDC Return to Work Guidance: Contingency & Crisis Strategies

Per CDC Return to Work Criteria guidance, health care facilities must be prepared for potential staffing shortages and have plans and processes in place to mitigate them, including considerations for permitting health care providers (HCP) to return to work without meeting all return to work criteria outlined.

CDC refers to the Strategies to Mitigate Healthcare Personnel Staffing Shortages document for information which provides both contingency and crisis strategies. Contingency strategies apply when staffing shortages are
anticipated and crisis strategies apply when staffing shortages are happening.

Facilities can activate these strategies based on their staffing situation and should document when they are activating these strategies with the reason why they were activated. Also, notify the local or state health departments of these actions.

For both scenarios below, a facemask instead of a cloth face covering should be used by all people in the building for source control during this time period while in the facility. After this time period, these staff should revert to their facility policy regarding universal source control during the pandemic.

  • A facemask for source control does not replace the need to wear an N95 or higher-level respirator (or other PPE) when indicated, including for the care of patients with suspected or confirmed COVID-19. Of note, N95 or other respirators with an exhaust valve might not provide source control.

Health Care Provider Asymptomatic with Unprotected Exposure to COVID-19
If not already done, allow asymptomatic HCP who have had an unprotected exposure to the virus that causes COVID-19 to continue to work.

  • These HCP should still be screened and also report temperature and absence of symptoms before starting each shift.
  • These HCP should wear a facemask (for source control) all the time while at work for 14 days after the exposure event.
  • If HCP develop even mild symptoms consistent with COVID-19, they must cease patient care activities and notify their supervisor or occupational health services prior to leaving work. These individuals should be prioritized for testing.

Health Care Provider with Suspected or Confirmed COVID19
If staffing shortages continue despite other mitigation strategies, consider implementing criteria to allow HCP with suspected or confirmed COVID-19 who are well enough to work but have not met all Return to Work Criteria to work.

  • If HCP are allowed to work before meeting all criteria, they should be restricted from contact with severely immunocompromised patients (e.g.,transplant, hematology-oncology) and facilities should consider prioritizing their duties in the following order:
    1. If not already done, allow HCP with suspected or confirmed COVID-19 to perform job duties where they do not interact with others (e.g., patients or other HCP), such as in telemedicine services.
    2. Allow HCP with confirmed COVID-19 to provide direct care only for patients with confirmed COVID-19, preferably in a cohort setting.
    3. Allow HCP with confirmed COVID-19 to provide direct care for patients with suspected COVID-19.
    4. As a last resort, allow HCP with confirmed COVID-19 to provide direct care for patients without suspected or confirmed COVID-19.

If HCP are permitted to return to work before meeting all Return to Work Criteria, they should still adhere to all Return to Work Practices and Work Restrictions recommendations described in that guidance. These include:

  • Wear a facemask for source control at all times while in the healthcare facility until all symptoms are completely resolved or until 14 days after illness onset, whichever is longer.
  • They should be reminded that in addition to potentially exposing patients, they could also expose their co-workers.
    • Facemasks should be worn even when they are in non-patient care areas such as breakrooms, laundry, and kitchen. They should adhere to social distancing as much as possible including during breaks outside the facility.
    • If they must remove their facemask, for example, in order to eat or drink, they should separate themselves from others (e.g. follow social distancing guidelines as much as possible).
Self-monitoring for symptoms and seeking re-evaluation from occupational health if respiratory symptoms recur or worsen.

COVID-19 Emergency Declaration Blanket Waivers for ICFs/IID

Dana Ritchie 

Today, CMS released additional blanket waivers to the healthcare community in order to provide the flexibilities needed to take care of patients during this public health emergency. Staffing and training modifications in Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICFs/IID) were included in this release. More waivers are yet to come down the way for ICF/IID providers.  A summary can be found below of what flexibilities are being provided for these providers in the release from CMS today. 

  • Staffing Flexibilities. CMS is waiving the requirements at 42 CFR §483.430(c)(4), which requires the facility to provide sufficient Direct Support Staff (DSS) so that Direct Care Staff (DCS) are not required to perform support services that interfere with direct client care.
  • Suspension of Community Outings. CMS is waiving the requirements at 42 CFR §483.420(a)(11) which requires clients have the opportunity to participate in social, religious, and community group activities.
  • Suspend Mandatory Training Requirements. CMS is waiving, in-part, the requirements at 42 CFR §483.430(e)(1) related to routine staff training programs unrelated to the public health emergency.  CMS is not waiving 42 CFR §483.430(e)(2)-(4) which requires focusing on the clients’ developmental, behavioral and health needs and being able to demonstrate skills related to interventions for inappropriate behavior and implementing individual plans.
  • Modification of Adult Training Programs and Active Treatment. CMS recognizes that during the public health emergency, active treatment will need to be modified. The requirements at 42 CFR §483.440(a)(1) require that each client must receive a continuous active treatment program, which includes consistent implementation of a program of specialized and generic training, treatment, health services and related services. CMS is waiving those components of beneficiaries’ active treatment programs and training that would violate current state and local requirements for social distancing, staying at home, and traveling for essential services only.

The full overview of the waivers CMS released today can be found here

Tuesday, April 21, 2020

A Virtual Continuing Education Opportunity that Delivers 70 Quality Sessions in One Affordable Package

Dave Kyllo

AHCA/NCAL has the online courses to help administrators, directors, and nurses meet their continuing education (CE) needs! The AHCA/NCAL 2019 Convention Education sessions are available to members and non-members in a package offering 70 online NAB and ANCC (nurses) approved courses. 

There are more than enough online courses in the package to meet most license requirements. Topics include those related to clinical practice, workforce, assisted living, technology, dementia care, and more!

The package is online, available 24-hours a day and the interface is easy. After purchasing the package, you choose a course, view the webinar, take and pass the quiz, print your CE certificate, and then self-report the course information to your NAB profile or nurse board.

The package costs $200. Once the package is purchased, access to the courses will be available until September 1, 2020. The package is for individual use only and access cannot be shared. Single courses are not available. You can access the package here.

Update on National Skilled Nursing Care Week May 10-16, 2020

After much consideration, the American Health Care Association (AHCA) has decided to recognize National Skilled Nursing Care Week (NSNCW) as scheduled May 10-16, 2020. Despite the challenges we face this year, it is more important than ever to recognize staff and residents in skilled nursing and post-acute care centers across the country.

We know that you and your staff are going to extraordinary lengths to keep residents safe from COVID-19. NSNCW presents an opportunity to acknowledge that and honor their hard work.

We encourage you to explore the following resources for ideas and suggestions on how you might celebrate despite the limitations of social distancing:

  • Visit NSNCW.org for a revised list of activity ideas and links to the bookstore for special NSNCW products. 
  • View, upload, and share messages of support at CareNotCOVID.com.
  • Go to Facebook and Twitter using #NSNCW and #CareNotCOVID to share activity ideas, videos, and messages. 

For the latest information and resources about COVID-19, visit ahcancal.org/coronavirus.

On behalf of the entire AHCA/NCAL team, we want to thank you for your heroic and unwavering commitment to caring for our most vulnerable population when they need you the most.

Wednesday, April 15, 2020

New Guidance and Additional Resources on COVID-19

Notification Guidelines for Confirmed COVID-19 Cases

AHCA/NCAL released new guidance and a press statement on notifying public health officials and stakeholders about confirmed cases of COVID-19 in long term care facilities. This guidance reinforces much of what long term care providers are already doing and are currently required to do in their states. Our guidance suggests that long term care providers should also report to the state survey agency, if you are not already, so that CMS and other federal agencies have another way to gather national information.

Collaborating with Hospice

AHCA/NCAL worked with National Hospice & Palliative Care Organization to develop joint guidance on the important role hospice plays during the spread of COVID-19 in nursing homes and assisted living. Hospice is an integral part of the resident's care team. As COVID-19 spreads, hospice may become even more important, including helping with grief counseling for not only families and residents, but for staff as well.

Action Brief on Infection Control Focused SNF Surveys 

March 23, 2020, CMS announced federal and state surveyors will conduct targeted infection control surveys of providers. They will base the survey on the abbreviated infection and prevention survey tool. AHCA developed an action brief to help centers navigate the focused surveys, including implementation and preparation strategies. Centers are strongly encouraged to enact peer monitoring, by all staff, to ensure just-in-time teaching practices that reflect appropriate infection control procedures.

New CMS Cohorting Guidance

On April 13, CMS released detailed guidance on long term care facility transfers. This matches the cohorting guidance that AHCA/NCAL shared previously.

All nursing homes and assisted living communities should make plans for cohorting residents even before COVID-19 enters the building. Cohorting is imperative to help control the spread of the virus. If possible, nursing homes and assisted living communities should also begin preparing wings, units or floors as “isolation units”. Isolation unit should be a separate, well-ventilated area, ideally with a separate entrance.

Recommendations for When a Resident Wants to Leave the Building 

AHCA/NCAL has developed recommendations to help you address when a resident wants to leave the building to go into the surround community and then return. This could introduce COVID-19 into the building and endanger others. Our recommendations include communicating with the resident and family, requiring isolation, and contacting the ombudsman and the local health department.

Financial Assistance for Skilled Nursing Centers

CARES Act Provider Relief Funds

On Friday, April 10, the U.S. Department of Health and Human Services (DHHS) released the first round of the $100 billion in relief funds to hospitals and other health care providers on the front lines of the coronavirus response. This funding will be used to support health care-related expenses or lost revenue attributable to COVID-19 and to ensure uninsured Americans can get testing and treatment for COVID-19. Learn more on the CARES Act Provider Relief Fund webpage and from AHCA’s summary on April 10.

For additional details, AHCA/NCAL has developed some FAQs specific to long term and post-acute care providers.

No-Interest COVID-19 Financial Support Available 

The Centers for Medicare and Medicaid Services (CMS) COVID-19 Accelerated and Advance Payment Program is a streamlined version of existing policy that allows Medicare Administrative Contractors (MACs) to issue no-interest short term loan payments in certain circumstances, including national emergencies. AHCA members and Independent Operator Council co-chairs Sarah Schumann and Mark Traylor, who submitted requests for and quickly received the accelerated payments, have the following recommendations for their peers:

“We strongly recommend that SNF operators take full advantage of the CMS COVID-19 Accelerated Payment Program. It’s a simple 5-10-minute process to complete and submit the application for an interest-free loan to assure adequate cash-flow during these challenging times. Since it must be paid back later, we suggest setting this advance into a separate reserve account to use as an emergency fund.”

Providers can learn more the Accelerated and Advance Payment Program though AHCA’s FAQ document here.

COVID-19 Testing in Long Term Care

On April 7, AHCA/NCAL provided a summary of the challenges LTC providers are facing in gaining access to COVID-19 testing. AHCA/NCAL has been seeking companies who can provide testing for LTC providers with reasonable turnaround times, and have put together a list of credible vendors here. This list will be continuously updated as more vendors are found.

If you know of any vendors that should be added to this list, please contact us at COVID19@ahca.org

Update on Personal Protective Equipment

Obtaining personal protective equipment (PPE) continues to be a challenge for long term care providers in many parts of the country. FEMA is now playing a primary national role in determining how PPE is distributed across the country. State and local governments are also playing a role in the supply and distribution of PPE. There are no quick fixes to the national PPE shortage.

Project N95
One coalition, Project N95, has formed to help link PPE suppliers with healthcare providers, including long-term care, in need.

Disposable Face Shields from MIT
The Massachusetts Institute of Technology (MIT) has designed and licensed a manufacturer to produce disposable face shields in high volume. These face shields do not replace the need for face masks such as N95s but do offer splash protection and can extend the useful life of N95 respirators and surgical masks. 

Long term care facilities facing shortages of face masks and other PPE should continue efforts to obtain N95s and other PPE even if they order the MIT face shields. The face shields cost $348.75 for a box of 125 ($2.79 each). Here is a link to MIT’s site with all the details and order form: mitshield.com.

More information on PPE availability, conservation and what to do when you are running low is available on our COVID-19 website under our Personal Protective Equipment section.

OSHA Issues Memoranda on Respiratory Protection

The Occupational Safety and Health Administration (OSHA) has issued two separate enforcement memoranda related to the use of respirators by healthcare and non-healthcare employers. This includes all long term care providers: skilled nursing, assisted living, and ID/DD providers. The memoranda address issues facing employers regarding the respirator shortage, giving employers limited relief from OSHA’s Respiratory Protection standard as a result from COVID-19.

The first memoranda gives employers relief to extend the use of National Institute for Occupational Safety and Health (NIOSH) – approved respirators and to permit reuse of them. The second memoranda allows employers in certain circumstances to use respirators approved by another country, where NIOSH-approved respirators are not available.  Employers must exhaust all NIOSH-certified respirators prior to use non-NIOSH-certified respirators. You can read more details including the guidance on Littler’s website.

Be Prepared - OSHA Requirements for PPE
AHCA/NCAL has learned that some members and other health care entities are receiving letters from OSHA regarding lack of PPE. AHCA/NCAL has consulted with our outside consultants who recommend preparing a plan with the following information: 

  1. If you are running low on PPE, follow the CDC guidance and guidance from your local health department.  
  2. Have a plan in place that deals with potential exposure to COVID-19 for employees, for example, what happens if a staff member has respiratory or other symptoms indicative of COVID-19 or tests positive with COVID-19.  
  3. Communicate this plan to all staff often and have it available for staff to review.    
Recording workplace exposures to COVID-19 - Occupational Safety and Health Administration (OSHA) 
OSHA recordkeeping requirement at 29 CFR Part 1904 mandate covered employers record certain work-related injuries and illnesses on their OSHA 300 log. While this requirement exempts recording of the common cold or flu, COVID-19 is a recordable illness when a worker is infected on the job if the following are met:

  1. Case is confirmed COVID-19  
  2. The case is work-related as defined by 29 CFR 1904.5 and  
  3. The case involves one or more of the general recording criteria set forth in 29 CFR 1904.7 
Visit OSHA’s Injury and Illness Recordkeeping and Reporting Requirements page for more information.

AHCA/NCAL Resources

  • A form letter providers can fill in when responding to OSHA inquiries due to complaints regarding limited or unavailable PPE.  
  • A document on OSHA guidance when PPE is critically low or unavailable including steps providers can follow.  
  • An explanation of OSHA and CDC guidance on N95 respirators that are critically low or unavailable. This resource provides five options with guidance on what to do for a limited supply of N95 or other respirators to no N95 or other respirators available.  
  • A document with updated guidance from OSHA on employer recording and reporting requirements for COVID-19.  

Affordable Online Dementia Care Training That’s Perfect for New Staff who Need to Learn the Basics Fast

Dave Kyllo

AHCA/NCAL members receive 15% off the purchase of any Healthcare Interactive® CARES online training program by using promo code AHCA15 at checkout.  CARES is the only online dementia training to be recognized by CMS. In addition, CARES online training is recommended by AHCA/NCAL to help reduce the off-label use of antipsychotics. 

That 15% discount makes CARES® very affordable. When AHCA/NCAL members purchase CARES® Dementia Basics™ 25-user package using the AHCA15 promo code, the final cost is less than $21 per staff person for four hours of highly quality dementia care training.  Bundle the Dementia Basics™ training with another training module and the cost is only $34 per staff member. 

HealthCare Interactive’s CARES® Dementia Basics™ module is recognized by the Alzheimer’s Association® for successfully incorporating the evidence-based Dementia Care Practice Recommendations in the following topic areas: Alzheimer’s and dementia, person-centered care, assessment and care planning, activities of daily living, and behaviors and communication. Providers who train their staff with HealthCare Interactive’s CARES® Dementia Basics™ online training program are eligible to purchase the optional Alzheimer’s Association essentiALZ® certification exams.

CARES training is unique because it includes direct video “before and after” training with an easy-to-use, easy-to-apply approach to dementia care called the CARES® Approach®. The CARES Approach can be used in any situation, with any person with dementia, at any stage of the disease. CARES has six training modules including:
CARES is also the only dementia care training to make extensive use of actual footage of real residents and real staff members (no actors) for truly authentic virtual training environment. Staff members will learn person-centered techniques to address issues, which often leads to behavior such as biting, kicking, punching, screaming, public urination and sexual behaviors.

To experience the CARES online training difference, test drive the first CARES Dementia Basics module at no cost. The training programs are easy to use, can be accessed from any computer, tablet, or mobile device and can be started and stopped as often as users wish.

Don’t forget to use promo code AHCA15 to receive 15% off your order. Feel free to call HealthCare Interactive at (952) 928-7722 with any questions about the training programs. 

AHCA Supports Bipartisan Bill to Expand Telehealth During COVID-19

Dana Ritchie 

On Friday, April 10, House Health Subcommittee Chairwoman Anna G. Eshoo (D-CA) and Representative Don Young (R-AK) introduced H.R. 6474, the Healthcare Broadband Expansion During COVID-19 Act, a bipartisan bill to provide $2 billion to expand telehealth and high-quality internet connectivity at public and nonprofit healthcare facilities, including mobile clinics and temporary health facilities deployed to respond to the coronavirus pandemic.

In a press statement from the offices of Reps. Eshoo and Young, it stated that healthcare providers pay an average of over $40,000 per year for broadband connectivity. The FCC’s Healthcare Connect Fund Program (HCFP) subsidizes 65 percent of the cost of broadband for eligible public and nonprofit rural healthcare facilities. H.R. 6474 expands the program to include rural, urban, and suburban healthcare facilities, including mobile and temporary facilities established to respond to the COVID-19 pandemic, and increases the subsidy rate to 85 percent. The bill also streamlines administrative requirements to ensure healthcare providers receive funding as quickly as possible.

On March 21st Rep. Eshoo sent a letter urging the FCC to expand its Rural Health Care Program, which HCFP is part of, in response to the coronavirus pandemic. A coalition of 48 healthcare organizations, including the American Health Care Association (AHCA), endorsed H.R. 6474. In addition to healthcare organizations, H.R. 6474 is broadly supported public interest groups; associations of local governments; and telecommunications companies and associations.

Monday, April 13, 2020

Updated List of Excluded Individuals and Entities (LEIE) Database File

The US Department of Health and Human Services, Office of Inspector General (OIG) has released its updated List of Excluded Individuals and Entities (LEIE) database file, which reflects all OIG exclusions and reinstatement actions up to, and including, those taken in March 2020. This new file replaces the updated LEIE database file available for download last month. Individuals and entities that have been reinstated to the federal health care programs are not included in this file.

The updated files are posted on OIG’s website at http://www.oig.hhs.gov/exclusions/exclusions_list.asp, and healthcare providers have an “affirmative duty” to check to ensure that excluded individuals are not working in their facilities or face significant fines.

Instructional videos explaining how to use the online database and the downloadable files are available at http://oig.hhs.gov/exclusions/download.asp.

As a best practice, long term care providers should check the LEIE on a regular basis.

Wednesday, April 8, 2020

CDC Issues Report on Assisted Living COVID Experience in Seattle



CMS released a Morbidity and Mortality Weekly Report (MMWR) last week (April 3) on an assisted living and independent living community in Seattle related to the COVID-19 outbreak. The report found that early intervention, increased social distancing among residents, and less contact with health care providers were possibly effective at minimizing the spread of the virus in an assisted living setting. More specifically:
  • residents were isolated in their rooms with no communal meals or activities
  • no visitors were allowed in the facility staff members were screened and symptomatic
  • staff members were excluded from entering
  • enhanced hygiene practices were put into effect, including cleaning and disinfection of frequently touched surfaces and additional hand hygiene stations in hallways for workers to use

Among the 142 residents and staff members tested during the initial phase, three of 80 residents (3.8%) and two of 62 staff members (3.2%) had positive test results.

The report also found that symptom screening is unlikely to be sufficient to identify all persons infected. Three of four residents who had positive test results were asymptomatic.

All assisted living providers are strongly encouraged to review CDC guidance for LTC Facilities as well as AHCA/NCAL’s guidance for ALs on limiting the spread of COVID-19, and are encouraged to minimize the number of interactions with residents by reducing the number of various (non-essential) people entering the building, targeting the number of interactions with residents, and instituting non-communal dining.


Please email COVID19@ahca.org for additional questions, or visit ahcancal.org/coronavirus for more information.

Tuesday, April 7, 2020

Get 90-Day Nationwide Exposure for the 30-Day Price for Your Job Listings on the AHCA/NCAL LTC Career Center

Dave Kyllo

The Long Term Care (LTC) Career Center gives unprecedented targeted national exposure because it connects with the Health Care Career Network by providing visibility on the network’s nearly 300 national and state health care organizations and societies. Serious health care candidates look for jobs on this national network built for health care employers to reach health care professionals.

Open positions can be posted through April 30 on the AHCA/NCAL LTC Career Center for 90 days at the $350 per 30-day posting price when you use promo code SPRINGSALE2020. That’s 60 extra days of national exposure for your job opening. This short video shows how easy it is to create an account and post a job vacancy.

Posting on the site gives even more value because employers who utilize the LTC Career Center receive free bonus exposure through rotating job listings on AHCA’s home page – the web site where long term care professionals go for news and information. In addition, employers that post vacancies through the AHCA/NCAL LTC Career Center get extra value through free rotating listings on the LTC Career Center home page.

Of course, the LTC Career Center is always free for job seekers and the LTC Career Center features many of the best positions the long term care profession has to offer. Graduates and experienced health care professionals utilize the Health Care Career Network to find the best health care openings.

Visit the LTC Career Center Employer Page or call Robin at 866-964-2765 x2736 for more information about posting job vacancies on the LTC Career Center and other discounted job listing packages.

National Public Health Week

Dana Ritchie 

This week (April 6-12, 2020) is deemed National Public Health Week (NPHW), and the American Public Health Association (APHA) has information and resources around this important week that can be found here. APHA notes on their website that, “In the midst of the most challenging public health crisis of our lifetimes, it's more important than ever to celebrate public health.” APHA is hosting NPHW events entirely online this year, to protect their partners and neighbors during the COVID-19 pandemic. They have listed ways here to celebrate this week while social distancing. 

Access to COVID-19 Testing in LTC

COVID-19 testing continues to be a significant point of concern for LTC providers. LTC residents with symptoms fall into priority category two for testing, according to CDC guidance. While not required, some state and local health departments and/or individual clinicians are using this guidance to prioritize testing. There is also a significant backlog of tests and growing shortage of testing supplies in labs across the country, which is also causing delays.

Members who are approached by companies selling antibody tests (blood tests with rapid result) should be aware that this is different than a PCR test and cannot diagnose a patient with COVID-19. Members should also verify that any company selling a test has an EUA from the FDA. More information is provided here. AHCA/NCAL continues to seek options for vendors that can provide testing for LTC and will continue to update you when new information is available.

The Toll COVID-19 Takes & Compassionate Care

As we have seen in the outbreak in Washington state, nearly half of all residents infected were hospitalized and approximately 20-25% died. While we are seeing similar widespread outbreaks in some facilities, others are experiencing only a small number of residents infected. Regardless, long term care staff need to prepare for residents becoming ill with COVID-19, possibly needing hospitalization, and unfortunately for some residents, succumbing to the virus.

You can take the following steps to help prepare.

Also make sure you are taking steps to ensure compassionate care. Advance care planning or end-of-life conversations can be difficult in the best of circumstances, let alone the current environment with restrictions, heightened emotions, and scarce resources.

Read more about steps you can take to be prepared as well as tips on having these conversations.

Every Interaction is a Risk

AHCA/NCAL has updated our resource “When COVID-19 Gets into Your Facility” as COVID-19 is increasingly impacting nursing homes and assisted living communities. Due to the rapid progression of this virus, centers should assume it is already in their surrounding community and may be in their facility. This resource outlines four action steps.

Similarly, it’s important to remember that COVID-19 spreads principally person-to-person. Every interaction between people increases the risk of spread, particularly now that the virus is in most areas of the United States.

The goal is to minimize the number of interactions with residents. This guidance provides some ideas on how to achieve this goal. It includes:

  1. reducing the number of various (non-essential) people entering the building; 
  2. targeting the number of interactions with residents by: 
    • reducing the number of different staff entering a resident’s room
    • increasing efficiency of tasks when entering in a resident’s room to decrease the number of times staff enter
AHCA/NCAL has also updated this cohorting consideration guide, as CMS released new guidance on April 2 related to this topic. All nursing homes and assisted living communities should make plans for cohorting residents now, even before COVID-19 enters the building per CMS guidance. Cohorting is imperative to help control the spread of the virus. If possible, nursing homes and assisted living communities should also begin preparing wings, units or floors as “isolation units”. Isolation unit should be a separate, well-ventilated area, ideally with a separate entrance.

CMS Issues New Recommendations to Nursing Homes, State & Local Governments

On Thursday, April 2nd, the Centers for Medicare & Medicaid Services (CMS), in consultation with the Centers for Disease Control and Prevention (CDC), issued new recommendations to state and local governments, as well as nursing homes, to help mitigate the spread of COVID-19 in nursing homes. Read more in Member Email Update #31. 

Make sure you are using PPE correctly and conserving supplies, as well as following current guidance and public health best practices. Here are some helpful links:

Wednesday, April 1, 2020

ICF/IIDs and PRTFs COVID-19 Guidance Released

Yesterday, the Centers for Medicare & Medicaid Services (CMS) released guidance for infection control and prevention of COVID-19 in Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF/IIDs) and Psychiatric Residential Treatment Facilities (PRTFs). CMS notes that these facility staff should regularly monitor the Centers for Disease Control and Prevention's (CDC) website for information and resources. These providers should also contact their state health agency if they have questions or suspect a client/resident of an ICF/IID or PRTF has COVID-19.