February 25, 2021
The federal government is sending Washington State a monoclonal antibody product to the Department of Health (DOH). The DOH can distribute it to skilled nursing facilities that are interested in receiving the product free of charge.

Several SNFs in Washington have successfully infused residents already. WHCA and other interested LTC stakeholders have been involved in a workgroup with DSHS and DOH to increase the availability and resources needed for SNF providers to administrator this medication to those COVID positive residents that meet the criteria. An identified barrier is licensed nursing staff time necessary to administer and monitor the resident post infusion.

An intervention identified to assist the facility with the infusion of monoclonal antibodies is the use of the DSHS Rapid Response Staffing Support teams to “back fill” facility staff to allocate staff time. A number of example policies and protocols have also been developed to assist a facility in the administration of monoclonal antibodies. Information about the product and how to access it is available here.  

Any facility able to abide by the requirements in the provider fact sheet will be eligible to receive the medication. If you have questions, please email Jennifer Dixon at DOH. If you are interested in the use and support of licensed nursing staff with the Rapid Response team to facilitate monoclonal antibody infusion, please email Elena Madrid.
On August 26, 2020, CMS issued QSO-20-38-NH that outlines details on how nursing homes are to comply with new interim final rule 483.80(h) requiring COVID-19 testing of staff. This regulation went into effect on September 2, 2020.

Testing of Staff and Residents in Response to an Outbreak
For the purposes of the CMS requirements set forth in F886, an outbreak is defined as a new COVID-19 infection in any healthcare personnel (HCP) or any nursing home-onset COVID-19 infection in a resident. A resident who is admitted to the facility with COVID-19 does not constitute a facility outbreak.

Upon identification of a single new case of COVID-19 infection in any staff or residents, all staff and residents should be tested, and all staff and residents that tested negative should be retested every 3 days to 7 days until testing identifies no new cases of COVID-19 infection among staff or residents for a period of at least 14 days since the most recent positive result.

WHCA has heard of recent citations under F886 for facility(s) following LHJ guidance for testing of staff and residents in response to an outbreak when the testing response allegedly does not meet the minimum CMS requirements outlined in the requirements of participation.

While the LHJ does have authority over outbreaks and testing, they do not have the authority to waive the Requirements of Participation, CMS requirements for a certified facility. Therefore, if the LHJ issues an order that is stricter or more comprehensive than the CMS requirement, the facility must comply. However, the facility cannot meet the CMS requirements with a standard/testing guidance that is less than the CMS requirement. If you have questions regarding the CMS Testing Requirements, please email Elena Madrid or call her at (800) 562-6170, extension 105.
Many facilities have asked us if they need to perform fit testing for N95 masks. The answer to that question is always YES. Assisted living and skilled nursing facilities must conduct fit testing and have a respiratory protection program in place in order to comply with OSHA/DOSH and infection control requirements. Whether there is a COVID-positive resident in your facility or not, you have to have N95 masks available and the proper fit testing completed—including the medical evaluation—or your facility is not in compliance and could be subject to citations and enforcement including fines, not to mention placing your staff and residents at risk. You do not need to fit test every employee in your building, but you must fit test those that are required to wear N95’s or any other tight-fitting respirator. 

The Department of Health (DOH) is offering another opportunity for small group fit testing coaching with a DOH occupational health nurse. The occupational health nurse will provide small group coaching for facilities and agencies who are doing their own fit testing with a qualitative fit testing kit. You can sign up for one of these complimentary sessions here. The practice sessions will last two hours and will be conducted via Microsoft Office Teams. You will watch live demonstrations, and then you will practice fit testing skills and receive feedback. There will also be time for questions.

You must have a fit testing kit on hand to participate in the training sessions. DOH is out of kits and is not able to send any out at this time (they are hoping to have more sometime in March). DOH will continue to offer the sessions monthly, and there will be additional opportunities. Do not let this stop you from starting your program now. Every facility at a minimum must have a Respiratory Protection Program in place immediately.

WHCA collaborated with Employer Resources Northwest (ERNwest) to create a respiratory protection program template you can customize to create a plan for your facility. We urge you to ensure your facility has its plan in place, has done fit testing, has fit testing equipment, N95 masks, and/or the proper documentation demonstrating your efforts to secure the proper equipment. We have heard from some facilities that have been cited and are now paying fines thousands of dollars in fines. If you have questions or need additional resources, please email Diana Hitchings or call her at (800) 562-6170, extension 116.
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.