Adapting Regulatory Policies and Practices During
COVID-19: Medication Training, CPR, and Assessments
As ALFs are adhering to restricted visits, resident outings, and isolating mandates and recommendations, they are unable to meet operational requirements and resident assessments as their standard operating procedures direct.
Examples include the 6-hour Assistance with Self Administration of Medication training that must be delivered in a face to face venue. We shared member concerns with the Agency about not being able to or risk the face to face classroom interaction. The Agency verified in the 4:15 p.m. Healthcare Provider Conference Call yesterday (3/26) that delivering the 6-hour training online would be acceptable when followed by a live return demonstration of competency by a nurse.
Similarly, ALFs with specialty licenses often bring in contracted clinicians to conduct a variety of resident assessments, including initial and quarterly health assessments. These additional visits are being modified or curtailed in compliance with restrictions to visits and outings. Members asked if they could utilize alternate methods such as Skype or Zoom to conduct mandatory nursing assessments in their efforts to minimize transmission risks. During the same call, the Agency responded that expanding ways to provide non-hands on care is appropriate if the goal of the assessment (or regulation) can be accomplished in the alternate mechanism of care delivery: this is in the vein of telemedicine.
Another example discussed (3/26) was the requirement that a CPR-certified person be in the ALF at all times. CPR certification renewal is a live, classroom based training and is currently unavailable or unadvisable for staff. Because certification could lapse, the Agency stated that ALFs should be reasonable in trying to provide the safety supported by the regulation and the Agency would be reasonable in their review of the modification.
As ALFs seek to provide care and services in a pandemic response that includes frequent Executive and Emergency Orders, a good rule of thumb in making adaptations is to develop a philosophy and/or policy that echoes the Agency’s statement:
“The organization will work to provide the resident and staff safety supported by regulation while recognizing that Florida’s regulatory bodies will reasonable in their review of the modification.”