Greetings!
This message includes:
- information from OLC on surveyor testing for COVID-19;
- registration information for the ECHO National Nursing Home COVID-19 Action Network kickoff calls; and
- new OSHA guidance.
Sincerely,
April Payne, MBA, LNHA
Vice President of Quality Improvement | Director of VCAL
Virginia Health Care Association | Virginia Center for Assisted Living
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Information from OLC on Surveyor Testing
We received the following update from Kim Beazley, deputy director of the VDH Office of Licensure and Certification (OLC), on nursing home surveyor testing for COVID-19.
Currently, CMS has stated that they do not have a policy on surveyor testing and are following CDC guidelines. CMS also stated that surveying is essential work. CMS does not consider surveyors as contractors or visitors. In addition, OLC has the following to add:
- surveyors are performing daily self screening
- surveyors participate in reasonable facility screening protocols upon arrival
- surveyors have been trained in how to don and doff PPE
- surveyors performing onsite surveys have been fit tested for N-95 masks
- surveyors are wearing full PPE, including N95 masks, gowns, gloves, face shields, bonnets, and shoe coverings
- surveyors do not have direct contact with residents while conducting the focused infection control surveys
- surveyors are practicing social distancing while in facilities
- surveyors' time in facilities is limited while conducting the focused infection control surveys
OLC continues to follow current guidance from CMS. In addition, to date, VDH has not initiated a policy for testing OLC surveyors, epidemiology staff and local health department staff who all provide onsite assistance and oversight to nursing homes.
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ECHO National Nursing Home COVID-19 Action Network
VHCA-VCAL has been in touch with entities in Virginia interested in serving as training centers for the ECHO National Nursing Home COVID-19 Action Network. This is a no-cost training and mentorship program creating a virtual learning community where nursing facility staff can learn from experts and each other to expand the use of proven best practices. The goal is to collaboratively advance improvements in COVID-19 preparedness, safety and infection control.
We will have more information to share as the Virginia training centers (academic medical centers) finalize their contracts with Project ECHO and the Agency for Healthcare Research and Quality.
October 13, 2020 | 3:00 – 3:30 pm
October 14, 2020 | 2:30 – 3:00 pm
October 15, 2020 | 12:00 – 12:30 pm
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New OSHA Guidance for COVID-19 and Resources
AHCA/NCAL now has an Occupational Safety and Health Administration (OSHA) Respiratory Protection Plan Template developed by our OSHA Experts at Littler. Providers should note that if respirators are being used (such as N95s) you must have a Respiratory Protection Program in place to comply with OSHA standards. OSHA has fined long term care providers for not having the protection plan in place during the COVID-19 pandemic. The template is designed to be reviewed and tailored by each individual facility. Facilities should review the Respiratory Protection Standard (29.C.F.R. 1910.134).
OSHA has released guidance for enforcement discretion when considering issuing citations for respirators and fit testing. This guidance applies only to fit-testing of NIOSH-approved tight-fitting Powered Air Purifying Respirators (PAPRs) used as a contingency capacity strategy when performing job tasks with high or very high occupational exposure risk to COVID-19. It does not apply to:
- PAPRs that have not been approved by NIOSH;
- PAPRs used by any workers with low or medium exposure risk to COVID-19;
- PAPRs used by any workers for protection against airborne hazards other than COVID-19 (e.g., chemical hazards); and
- Loose-fitting hooded PAPRs that do not require fit-testing.
Due to N95 shortages, employers should prioritize the use of fit-testing supplies to protect employees who must use respirators for high risk procedures.
OSHA will, on a case-by-case basis, exercise enforcement discretion when considering issuing citations for fit-testing and respirators when an employer has:
- Provided NIOSH-approved tight-fitting PAPRs to protect personnel against COVID-19 using a high efficiency (HE) particulate cartridge or filter, when initial and/or annual fit-testing is infeasible due to shortages of N95, N99, N100, R95, R99, R100, P95, P99, and P100 respirators and/or fit-testing supplies;
- Monitored fit-testing supplies and made good faith efforts to obtain fit-testing supplies;
- Implemented, to the extent feasible, engineering controls, work practices, and/or administrative controls that reduce the need for respiratory protection, such as using partitions, restricting access, and cohorting patients; and
- Maintained a fully-compliant RPP, other than fit-testing requirements, including ensuring personnel are informed of new policies and trained on new procedures, ensuring employees receive required medical evaluations, ensuring batteries and filters for PAPRs are well maintained to provide positive pressure throughout the entire shift or procedure, and ensuring employees wearing tight-fitting PAPRs maintain neatly trimmed facial hair that does not compromise the seal of the respirator or come between the sealing surface of the facepiece and the face, and that does not interfere with valve function.
Please note - Where the above efforts are absent and respiratory protection use is required, or voluntary use is permitted, and an employer fails to comply with applicable medical evaluation, fit-testing, maintenance, care, and training requirements, citations can be issued.
OSHA issued frequently asked questions regarding COVID-19 reporting obligations. In the FAQs, OSHA has clarified what is considered an “incident” in the case of COVID-19, which triggers the time period for calculating whether a case meets the reportability criteria. The term “incident” is defined by OSHA as an exposure to COVID-19 in the workplace as opposed to when an employee develops symptoms or tests positive for COVID-19. Additional information on reporting in-patient hospitalizations and employee deaths, including OSHA’s definition of in-patient hospitalizations can be found in the updated AHCA/NCAL OSHA resource on reporting and recording OSHA standards.
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Upcoming Events
September 29 – October 29, 2020
October 8-31, 2020
November 17-18, 2020
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