COVID-19 UPDATE #12
March 22, 2020
FREQUENTLY ASKED QUESTIONS
The COVID-19 pandemic affecting our region brings new challenges each day. Over the past few weeks, the WHCA team has been working with the office of the Governor, health officials at both the state and federal level, the professional team at AHCA/NCAL, and our members to navigate through the COVID-19 crisis. We have developed a list of frequently asked questions for assisted living and for skilled nursing providers to help guide others as the virus spreads, affecting more communities across Washington. Our expert staff continues to be available to help, and we point to these FAQs as well as the page devoted to the COVID-19 crisis on the WHCA website.
INTERIM GUIDANCES ON SNFs ACCEPTING PATIENTS FROM THE HOSPITAL
AHCA is issuing interim guidance to help skilled nursing facilities make decisions about accepting hospital discharges to SNFs during the COVID-19 pandemic. The decision making and guidance will likely change as the prevalence of COVID-19 varies in communities and hospital surge increases in the community. This guidance is designed to help reduce the risk of admitting someone with COVID-19 into your building, along with the steps you should take to prevent any spread. 
 
Transfers from the hospital: A positive test for COVID-19 or a person with fever or respiratory symptoms does NOT need to be hospitalized. They should be put in contact precautions and follow CDC guidance for COVID-19 positive or presumptive cases in long term care. If a resident requires IV fluids, oxygen and other treatments due to their respiratory symptoms, Medicare will allow you to switch the person over to Medicare Part A without a three-day skilled nursing facility stay . Discussion with families and residents should occur about the risks of hospitalization with COVID-19 during this pandemic. Read more .
DEPARTMENT OF HEALTH ISSUES PERSONAL PROTECTIVE EQUIPMENT DISTRIBUTION GUIDELINES
Over the weekend, the Department of Health revised its PPE prioritization list. The state’s prioritization list does not guarantee that every order that meets the priority criteria will be fulfilled, and it does not ensure that complete orders will be fulfilled. The DOH Secretary of Health, State Health Officer, or Unified Command may modify the criteria based on emerging response needs.
  • The first tier of recipients is long term care facilities with confirmed COVID-19 cases, hospitals with the greatest number of confirmed cases, emergency medical services and first responders who are asked to transport confirmed patients, and health care workers supporting long term care facilities with confirmed cases.
  • The second tier of recipients comprises health care facilities with fewer confirmed cases, congregate locations with confirmed cases (such as jails, shelters or dormitories), other EMS services, and Department of Health-run isolation and quarantine facilities.
  • The third tier of recipients is quarantine and isolation facilities run by other jurisdictions, followed by skilled nursing facilities, other health care facilities, and outpatient facilities.
  • The fourth tier of recipients is homeless shelters and other congregate locations, and family members of confirmed cases who are at home.
 
The prioritization of N95 respirators (masks) are only distributed to facilities in the first tier. Additionally, they are only distributed at the highest priority to locations that perform aerosol-generating procedures. The prioritization of personal protective equipment may evolve as this outbreak continues. Read more .
MAKING DECISIONS ON ESSENTIAL STAFF ENTERING YOUR BUILDING
When deciding if a person needs to enter your building (including employees or outside contractors such as therapy , pharmacy, lab, portable x-ray, mental health provider, repair technicians, and others), all long term care facilities should consider the intent of the federal and state guidance on visitation and building entry restrictions.
The intent is to restrict entry of as many people as possible to reduce the risk of
COVID-19 entering and/or spreading in the building. Anybody entering the building must comply with the most current federal and state COVID-19 guidelines. Entering multiple buildings during the day should be discouraged, or increased attention to infection control processes should be applied in cases when it is essential.
  
This decision needs to be balanced with meeting the needs of the resident. The risk-benefit trade-off needs to be made on a case-by-case basis and should be informed by the high mortality associated with contracting this virus in the elderly. This decision process should also be evaluated and adjusted as necessary as the COVID-19 situation evolves in your local community and building.
UTILIZING NON-DIRECT CARE STAFF TO SUPPORT NEEDS
COVID-19 has interrupted usual daily operations in all long term care facilities. This means the usual duties of some direct or non-direct care staff are on hold or not urgent during this pandemic. Thus, there is opportunity to engage those staff in supporting activities that must continue despite the pandemic disruptions. Below are some ideas to consider.
Typical Nurse Aide Duties to be Stopped and Shifted to Other Non-Direct Care Staff: 
  • Deliver water and snacks 
  • Deliver linen and supplies 
  • Restocking supplies 
  • Assisting residents in wheelchairs to/from events (bathing, etc.) 
  • Take menu/orders from residents 
  • 1-on-1 with resident who have behavioral challenges or need socialization 
  • Deliver meals to residents during mealtime 
  • Applying/removing glasses and hearing aids to residents 
  • Bed making 
  • Responding to call lights 
  • Assisting with feeding non-choking or non-aspiration risk residents 
  • Doing errands for the resident 
  • Doing personal care such as combing hair or washing faces/hands 
  • Stay with resident while in the bathroom to free up NA to do other tasks while waiting to transfer 
 
Nurse and Nurse Aide duties that could be supported by physical and occupational therapy and speech-language pathology staff: 
  • Restorative and functional ADL and mobility maintenance services 
  • Perform and document routine vital signs, orthostatic BPs, etc. 
  • Assisting to feed moderate risk residents (history of some choking issues) 
  • Any other basic support duties that could also be performed by non-direct care staff 
 
Typical Nurse (or some medication aide) duties to be shifted, stopped, or requests to reduce/discontinue: 
  • Request discontinue of non-critical medications (e.g. vitamins, calcium) 
  • Request discontinue or reduced blood sugar checks (e.g. decrease to daily or weekly) 
  • Request discharge of sliding scale insulin and standard/set amount of long-acting insulin administered every day 
  • Request to reduce dressing changes to daily or biweekly (as appropriate) 
  • Routine vital signs decrease to weekly or monthly (as appropriate) 
  • Orthostatic B/Ps - reduce to one time daily or weekly (as appropriate
  • Stop routine monthly vital signs 
DELAYING IMPLEMENTATION OF OCTOBER 1, 2020 MINIMUM DATA SET 3.0 V.1.18.1 RELEASE
CMS is delaying the Minimum Data Set (MDS) 3.0 v1.18.1 release, which had been scheduled for October 1, 2020, in response to stakeholder concerns. The MDS changes CMS planned for October 1, 2020, will now be delayed. CMS staff are actively engaged in discussions with various stakeholders regarding the various changes, the impacts of these changes, and the compressed timeline to educate and train facility staff and update software and IT systems.
CMS PROVIDES MEDICARE PAYMENT FLEXIBILITIES RELATED TO COVID-19
CMS has provided Medicare Advantage (MA) organizations with flexibilities. However, it is up to each individual MA plan to determine what flexibilities they will implement. It also applies to Medicare Medicaid Plans (MMPs). Click here to review a complete list of items MA organizations have the ability to do and the requirements of MA organizations during a disaster.
Changes that benefit the enrollee can be effective immediately without the 30-day notification requirement (examples include reductions in cost sharing and waiving prior authorizations).
COMMUNICATING AFTER A CONFIRMED CASE
It is important to keep families and staff informed once you have confirmed a case of COVID-19 in your building. To help with communication to all stakeholders, AHCA/NCAL has developed a sample letter  for families and staff and talking points  for the media and broader public.
DEAR ADMINISTRATOR LETTER TO ASSISTED LIVING PROVIDERS HIGHLIGHTS GOVERNOR'S PROCLAMATION ON WAIVERS
On March 20, 2020, Residential Care Services (RCS) issued an amended letter to include additional information on the waivers Governor Inslee has made via Proclamation 20-18 waiving and suspending some licensing and survey activities in assisted living. The following items are also waived or suspended at this time:
  • Full licensing inspections (RCW 18.20.110)
  • To ensure the administrator and all caregivers employed directly or by contract have a national fingerprint background check (WAC 388-78A-2462(2)(b)
  • To prevent unsupervised access to residents by caregivers or administrators beyond one hundred twenty days of hire when not disqualified based on the results of the Washington state name and date of birth background check, and when the results of the national fingerprint background check are pending (WAC 388-78A-24681 and WAC 38806-0500 through WAC 388-06-0540)
  • Washington State Patrol and Federal Bureau of Investigation fingerprint background checks and national sex offenders registry background checks (RCW 74.39A.056(1)(b)(i), RCW 43.20A.710(2), and RCW 43.43.837(1))
  • To reasonable access by their representative, an entity or individual that provides health, social, legal, or other services (RCW 70.129.090(2))
RESIDENT LAUNDRY GUIDANCE WITH COVID-19 AND WHEN FAMILIES WANT TO DO RESIDENTS' LAUNDRY
With the restriction around non-essential visitors to skilled nursing centers and assisted living communities to minimize the risk of spread of COVID-19, there have been many questions on handling residents’ personal laundry, including for those who may have previously had their laundry done by a family member.  
AHCA/NCAL has developed some additional guidance  on this. You can also follow CDC guidelines for environmental infection control in healthcare facilities. CDC states that, “Infection has not been linked to laundry procedures in residential-care facilities, even when consumer versions of detergents and laundry additives are used.”
DOSH AND L&I RELEASE TEMPORARY ENFORCEMENT GUIDANCE REGARDING FIT TESTING FOR N95 MASKS
This directive provides temporary enforcement guidance to Compliance Safety and Health Officers for enforcing Chapter 296-842 WAC, Respirators, with regard to supply shortages of N95 filtering facepiece respirators due to the COVID-19 outbreak. The Respiratory Protection standard has specific requirements, including a written program, medical evaluation, fit-testing, and training, that employers must follow to ensure workers are provided and are properly using appropriate respiratory protection when necessary to protect their health.
BEWARE OF COVID-19 SCAMS OFFERING TO SELL PPE AND OTHER SUPPLIES
Providers are receiving vendor emails or other contact offering PPE supplies, and some may not be legitimate vendors or businesses. Please beware that some offers are scams and are not credible businesses. To help you spot the difference between legitimate businesses and scams, the Federal Trade Commission (FTC) has provided some general guidance on COVID-19-related scams. AHCA/NCAL has also compiled a list of helpful questions to ask yourself and the business in question.
NON-URGENT MEDICAL CARE PROHIBITION
Governor Inslee issued a proclamation prohibiting non-urgent health care treatments for three months. The Governor’s proclamation prohibits all hospitals, ambulatory surgical facilities, dental, orthodontic and endodontic offices in Washington State from providing health care services, procedures, and surgeries that, if delayed, are not anticipated to cause harm to the patient within the next three months, with some exceptions. This does not include outpatient visits delivered in hospital-based clinics. Click here for complete proclamation.
BUSINESS RELIEF DURING COVID-19 PANDEMIC
The Washington Department of Revenue is taking action to help businesses impacted by the COVID-19 outbreak. This relief addresses a broad range of taxes: business and occupation tax, real estate excise tax, and other taxes administered by the Department. Click here to view the Department of Revenue’s resources for impacted businesses.
DEPARTMENT OF HEALTH AND LEADING EXPERTS TO HOST Q&A
You are invited to join leading experts from the Department of Health and other agencies and professional organizations for online Q&A sessions specific to COVID-19. The maximum capacity for participants is 1,000, so we request that colleagues and groups log in together where practical and safe to do so. There will be a chat feature enabling people to submit questions for the panel to answer. For those who can only join by telephone, a time will be designated to unmute lines for conversational questions. The Q&A sessions are not being recorded, but the DOH will work on creating a FAQ sheet that can be shared. The following dates and times are available on a first-come, first-served basis:
 
March 26, 2020 | 11 AM
April 2, 2020 | 11 AM
April 9, 2020 | 11 AM
April 16, 2020 | 11 AM

Click here for instructions to join the meetings/calls.