Thank you for reading - we will continue to send updates as we receive new information.
Tuesday, December 15, 2020
Watch Your Email & Plan to Join Us for FSLA's End of Year Zoom Call
for Members and Non-Members
Wednesday, December 16
NEW TIME -- 3:00 p.m. EST
Sally West, Walgreens;
Brooke Flaherty Tiner, CVS;
Lisa Rogers, RN, Elegance Senior Living; and
AHCA (invited)
Mark Your Calendar and Plan to Participate . . . AHCA's ALF Rule Workshop Scheduled for Thursday

Don’t forget to mark your calendars and plan to attend AHCA’s first rulemaking workshop on the implementation of HB 767, the ALF Modernization Act – specifically:
  • Assistive devices
  • Physical restraints
  • Third-party provider discussions and documentation
  • Infection control procedures
  • Assistance with self-administration of medication
  • ALF Core Training Requirements

If you are not able to attend the Rule Workshop, FSLA will be participating, providing comments, and will keep you updated as the rule progresses. After you have had an opportunity to read the proposed rules, please do not hesitate to send us your comments at

The Rule Workshop will be held on Thursday, December 17, from 10 AM-11AM, EST, via teleconference (1-888-585-9008; Conference room number 476-211-242#).

The notice, agenda, draft rule text, and incorporated materials are available by clicking below.

Rule Chapter 59A-36, Assisted Living Facility

  • 59A-36.007, Resident Care Standards
  • 59A-36.008, Medication Practices
  • 59A-36.028, ALF Minimum Core Training Curriculum Requirements

The Agency proposes to revise rules 59A-36.007, 36.008 and 36.028, F.A.C., pursuant to HB 767 (2020) which amended sections 429.41, 426.256, and 429.52, F.S., respectively, to provide for the use of physical restraints, the option for a resident to waive being orally advised of medication names and dosages, and the establishment of requirements by rule for core trainer registration and removal.

Workshop Information:
No public face-to-face meeting will be held; participate by using the Open Voice conference line: 1-888-585-9008; Conference room number 476-211-242#

Separate Completed Consent Forms Required for Each Vaccine Dosage

Several members asked if Walgreens and CVS could combine the consent for each vaccination into one authorization form instead of the resident and/or family member, POA or guardian being required to sign two forms.

The answer is unfortunately, No. Federal Law (Title 42) requires that a consent form be signed prior to the administration of every dose of a vaccine. Pharmacies cannot legally give the second dose without collecting a second consent form.
FDA Not Requiring Written Consent, But . . . Providers Still Required to Document in Resident's Medical Record

Yesterday, another question was asked about whether pharmacies would allow verbal consent authorizations for the vaccines. So, we reached out to AHCA for their thoughts.

"Although verbal consent is acceptable under the federal side, the provider would still be expected to document in the residents medical record that consent was provided, to include date, time in addition to risk and benefits explained.

AHCA does not regulate pharmacies, but since these vaccines are being approved under Emergency Use Authorization, the FDA is not requiring written consent. However, each vaccination organization (Walgreens, CVS, Department of Health) will have a consent form.  

The consent should be provided by the party doing the vaccination and is specific to the vaccination provided. (Pfizer will have a different form than Moderna). In all cases, the Department of Health will have their own form, Walgreens and CVS will also have their own forms."

  • CVS Information
The CVS consent forms will be sent to the facilities as they are scheduled. A copy is also available on the CVS website. Below is a brief update on recent activities:
  • CVS Health (Omnicare) began communicating with LTC facilities in early December
  • CVS Health has made contact with most facilities, but outreach continues
  • Facilities should be instructed to check their junk / spam inboxes to verify whether the CVS Health and/or Omnicare outreaches are reaching intended audiences. We are noting that some emails are being routed to these locations.
  • A comprehensive website with supporting resources for LTC facilities and state contacts can be found at
  • If a facility has not either received an email or a phone call from CVS Health, they should be prompted to take the following action beginning today:
  • Visit the vaccine clinic homepage and update the facility contact information:
  • Send an email to CVS Health:
  • In the email subject line, please include the word “CONTACT”
  • In the email body, please include:
  • Facility name and address
  • Facility point of contact: name and contact information
  • Questions from LTC facilities, at any time, can be routed to