November 19, 2020
Washington counties have seen a large increase in COVID-19 cases over the last few weeks. Positivity rates in many counties (including King, Pierce and Snohomish) are greater than 5%. We would like to bring your attention to the CMS Guidance, where skilled nursing facilities in a county with >5% positivity rates must routinely test all staff weekly. Additionally, Public Health officials are encouraging assisted living facilities to test staff weekly, or as frequently as possible.

Of note, if a county has a positivity rate of 10% or greater, CMS recommends nursing home staff be tested twice weekly. Currently, some areas in south King County have a positivity rate greater than 10%, and it is possible that King County as a whole will exceed a 10% positivity rate in the future. In a recent communication, King County Public Health Department notes facilities in south King County could consider increasing testing to twice weekly and all King County facilities should start preparing for this possible outcome.

We understand this is a burden to facilities; however, increased testing is an impactful action. Early identification is key to reducing the severity of a facility’s outbreak.

You can review the CMS data tracker here. In addition, here is the most recent CMS county-by-county positivity spreadsheet.
After discussion between DSHS, DOH, and the Governor’s Office, we have learned the following regarding LTC community fitness centers:

At this time, the facilities with long term care residents and independent living residents are required to follow different parts of the Governor’s proclamation, depending upon the resident. Independent living facilities, and the residents in those facilities, are bound by the portion of the proclamation that closes fitness centers. LTC facilities and the residents in LTC facilities still follow Proclamation 20-66, (with the exception of the visitor provisions).

During much of the pandemic, LTC facilities have been advised that physical therapy rooms and fitness rooms can be utilized with the following recommendations:
  • Phase 1 - should only have one resident at a time in the room, the resident wears recommended PPE for the situation, all equipment must be thoroughly sanitized between residents, and if a staff member is in the room, they are more than six feet away or wear appropriate PPE to account for the increased respirations that occur during exercise.
  • Phase 2 - allows for more than one resident in the room as long as there can be increased social distancing (beyond six feet) to account for the increased respirations that occur during exercise. All other Phase 1 criteria listed above also apply.
According to DSHS, given all of the above information, at this time LTC facilities would be able to continue using fitness facilities as they have been under the “Safe Start for LTC” plan. Long term care providers will be able to allow the long term care residents to continue using the fitness facilities located in their program, but they would not be able to allow the independent living residents to also use these facilities.
Independent living providers will need to close the fitness facilities located in their programs as they are bound by the closure requirements in the Governor's proclamation. If long term care residents had been using these facilities, they would not be able to do so at this time.

We realize this may cause hardship when only certain residents will be able to utilize the fitness centers. If it will cause more difficulty to manage who is able to use the fitness center, the provider may use their discretion in closing the center temporarily.
In a Dear Administrator letter to all providers dated November 18, Residential Care Services provides amendments to the Dear Administrator letter of November 17. It is amended to clarify the difference between visitation limitations related to end-of-life visits and essential support persons, and provide that window visits are allowed as an option for outdoor visitation. The letter also highlights that the visitor restrictions apply to all four phases at this time.

In addition, the letter provides clarity that residents have the right to leave the facility and this may result in them participating in holiday gatherings outside the facility or home. The provider should perform the risk assessment to identify the level of risk and implement any measures as indicated by the risk assessment upon the resident's return. The letter directs providers to reach out to their local RCS field manager or local health jurisdiction if they have questions.
The Department of Health and Human Services (HHS) has released information on the reporting of information relative to the Provider Relief Fund (PRF). HHS is collecting information on coronavirus (COVID)-related expenses and lost revenues due to COVID. The scope of reporting and the methodology that is proposed to be applied is significantly different than discussed in documents provided during the pandemic. The information provided here is based on information available on November 2, 2020, and provided by HHS.

It is important to understand the changes in revenue and expense between 2019 and 2020, the funds from outside sources, and the interaction between the multiple funding programs (PRF, PPP, Medicaid). The reporting system opens for providers on January 15, 2021, with a reporting deadline of February 15, 2021. For those providers that did not fully expend PRF funds prior to December 31, 2020, there is a final reporting deadline of July 31, 2021, for the period ending June 30, 2021. Additional information is available here. For questions regarding this information and available services, please contact Consolidated Billing Services, Inc., Bill Hartung, Director of Reimbursement at (509) 448-2067, extension 210, or Bill Ulrich, President/CEO at (509) 448-2067, extension 202.
On November 18, CMS released an alert regarding holiday visitation. During the holidays, facilities, residents, and visitors should continue to follow the guidelines for visitation and adhere to the core principles of infection prevention, such as remaining six feet or more apart, wearing a face covering at all times, and limiting the number of visitors in the nursing center at any one time. Families, residents, and providers need to work together to take precautions during the holidays to help reduce the risk of spread while supporting family and resident engagement as much as possible using these core infection prevention practices. 

CMS recommends against residents leaving the nursing center during the public health emergency because it increases the resident’s risk for exposure to COVID-19. The risk may be further increased by factors such as a resident’s health status, the spread of COVID-19 in the community (e.g., cases or positivity rate), or attendance at large gatherings. Read more.
AHCA/NCAL updated the 3-Day Stay and Benefit Period Waivers for Medicare Part A SNF PPS Fact Sheet here as well as the accompanying webinar here. Read more.
AHCA/NCAL will be hosting office hours on Monday, November 23, at 11 AM PST to provide a high-level overview of the COVID-19 monoclonal antibody and review what facilities need to know about this treatment. There will be a question and answer session at the end. Providers are encouraged to register for this training here
The Centers for Medicare & Medicaid Services (CMS) is publicly recognizing the 1,092 nursing homes at which 50% or more of their staff have completed CMS training designed to help staff combat the spread of coronavirus disease 2019 (COVID-19) in nursing homes. CMS applauds these facilities for taking this critical step to equip their staff with the latest information regarding infection control, vaccine distribution, and other topics.

There are 125,506 individuals from 7,313 nursing homes who have completed the training. This represents approximately 12.5% of the approximately one million nursing home staff in the country. With today’s announcement, CMS is calling on nursing homes to take action, urging them to require their staff to take this free training, as part of the Trump Administration’s continued efforts to keep nursing home residents safe.

The training modules for frontline staff address basic infection control and prevention - some of the most common concerns found by surveyors and Federal Task Force Strike Teams (teams of federal staff deployed to facilities with high numbers of cases). The modules are focused on the most urgent needs of frontline nursing home staff and include:
  • Module 1: Hand Hygiene and PPE
  • Module 2: Screening and Surveillance
  • Module 3: Cleaning the Nursing Home
  • Module 4: Cohorting
  • Module 5: Caring for Residents with Dementia in a Pandemic

The training modules for management are comprehensive, focusing on infection control and cleanliness but also larger institution-wide issues like implementation of telehealth, emergency preparedness, and vaccine delivery. They include:
  • Module 1: Hand Hygiene and PPE
  • Module 2: Screening and Surveillance
  • Module 3: Cleaning the Nursing Home
  • Module 4: Cohorting
  • Module 5: Caring for Residents with Dementia in a Pandemic
  • Module 6: Infection Prevention and Control
  • Module 7: Emergency Preparedness and Surge Capacity
  • Module 8: Addressing Emotional Health of Residents and Staff
  • Module 9: Telehealth for Nursing Homes
  • Module 10: Getting Your Vaccine Delivery System Ready

If a nursing home’s staff is unsure which training module best meets their needs, CMS is offering an online self-assessment tool here to help them identify their needs and suggest the appropriate training modules that best reflect those needs. A certificate of completion is offered for each completed training course. For anyone interested, the training is free to access on a public CMS website; instructions on how to create an account and take the training are available here. The list of nursing homes at which 50% or more of staff have completed CMS COVID-19 training is here.
WHCA continues to post resources and information as it becomes available on our website. If you have questions or need additional information, please call the WHCA office at (800) 562-6170.