April 8, 2020
The Nursing Care Quality Assurance Commission has been busy implementing the Emergency Volunteer Health Practitioner (RCW 70.15) program. Since the Legislature passed RCW 70.15 in 2018, the COVID-19 pandemic is the first time this program has been implemented.
A number of updates have been made to the Department of Health’s website  about the program. A few highlights of these updates include:
  1. Individual healthcare provider applicants now register online, instead of using a paper application. This decreased the processing time. Instructions to complete the online registration are available on the DOH website.  
  2. New information for Healthcare facilities: Healthcare facilities who want to request approved volunteers, or want to request to activate specific staff under this program as part of their own surge planning, need to complete a healthcare facilities request form. This information is necessary to help DOH to quickly support each request. DOH currently has more than 700 approved volunteers who are eligible to be placed.
  3. Facilities requesting to activate specific volunteers should complete this spreadsheet. Please be sure all fields are complete, they are all required to complete the process. Please do not include any additional fields beyond information on additional licenses a volunteer has.
  4. The frequently asked questions (FAQ) have also been updated and divided into questions for volunteers and questions for healthcare facilities.

We have received questions about the Department of Health’s authority under RCW 70.15.030 to regulate coordination of volunteers and how that intersects with facility and health system surge staffing. The Department has broad authority for volunteers activated under this program that includes where they work, for how long, and what types of providers may volunteer.
We want to be clear that the Department’s  current priority  is supporting health systems and facilities with their own staffing surge plans. Health systems or facilities can make a request to have approved volunteers activated for their specific needs. DOH is also working to support requests for healthcare facilities that need volunteers to ensure adequate staffing.
In the closing days of the legislative session, $200 million was allocated for emergency response to the coronavirus crisis. Since then, WHCA has pressed the state for access to this funding. The funding is needed for our assisted living members as well as our skilled nursing providers. The state has been slow to respond, and we are losing our patience. Therefore, we were surprised to read this newspaper article that concludes that the state has already blown through 60 percent of the emergency funding without giving any consideration of long term care providers.
DSHS issued a Dear Provider letter on April 7, 2020 (ALF #2020-014; NH #2020-016) . This letter clarified that when a resident is nearing death, families and hospice staff may visit the resident. All visitors must still be screened and may not be allowed to enter if they show signs or symptoms of COVID-19.
The Washington State Department of Health (DOH) has been the “lead” in providing state-specific guidance for long term care facilities throughout this COVID-19 outbreak; local health jurisdictions have served as the primary point-of-contact for facilities experiencing active COVID-19 cases. The local health jurisdiction may choose to impose stricter isolation or quarantine orders, as well as increased resident and/or staff monitoring for individual facilities or facilities within a specified geographic area. Likewise, these agencies may impose stricter methods to minimize risk of COVID-19 spread by mandating partial or full personal protective equipment (PPE) be worn by staff. Chelan-Douglas County health jurisdiction has imposed such an expectation on all senior housing and long term care facilities within their vicinity, and more jurisdictions may instill similar expectations. It is important to monitor your local health jurisdiction’s communication and respond accordingly.
DSHS/RCS issued a Dear Provider Letter April 6, 2020 , announcing limited availability of PPE items for long term care facilities. It is highly recommended providers continue requesting PPE through the local health jurisdictions first, however. To submit an order to DSHS, complete this online form .
The Occupational Safety and Health Administration (OSHA) has issued two separate enforcement memoranda related to the use of respirators by healthcare and non-healthcare employers. This includes all long term care providers: skilled nursing, assisted living, and ID/DD providers. The memoranda address issues facing employers regarding the respirator shortage, giving employers limited relief from OSHA’s Respiratory Protection standard as a result from COVID-19.

The first memoranda gives employers relief to extend the use of National Institute for Occupational Safety and Health (NIOSH)-approved respirators and to permit reuse of them. The second memoranda allows employers in certain circumstances to use respirators approved by another country, where NIOSH-approved respirators are not available. Employers must exhaust all NIOSH-certified respirators prior to use of non-NIOSH-certified respirators. You can read more details, including the guidance, on Littler’s website
Be Prepared! OSHA Requirements for PPE: It has also come to the attention of AHCA/NCAL that some members and other health care entities are receiving letters from OSHA regarding lack of PPE. AHCA/NCAL has consulted with our outside consultants who recommend preparing a plan. Here are some items that should be considered. If you are running low on PPE, follow the CDC guidance and guidance from your local health department. Have a plan in place that deals with potential exposure to COVID-19 for employees, for example, what happens if a staff member has respiratory or other symptoms indicative of COVID-19 or tests positive with COVID-19? Communicate this plan to all staff often and have it available for staff to review.

Recording Workplace Exposures to COVID-19: OSHA recordkeeping requirements at 29 CFR Part 1904 mandate covered employers record certain work-related injuries and illnesses on their OSHA 300 log. While these requirements exempt recording of the common cold or flu, COVID-19 is a recordable illness when a worker is infected on the job if the following are met: 
  1. Case is confirmed COVID-19;
  2. The case is work-related as defined by 29 CFR 1904.5; and 
  3. The case involves one or more of the general recording criteria set forth in 29 CFR 1904.7.
There are currently two different types of COVID-19 tests: molecular and serological. These types are not interchangeable and the results, particularly of the serological test, may be misleading.
The molecular test is currently the most commonly used to diagnose COVID-19. Approved by the FDA, the molecular test involves inserting a six-inch-long cotton-tipped swab in the back of the nasal passages. Depending on the lab, this test may need to be mailed in or processed at the point of care. Some test results can take as long as a week to process, while newer rapid diagnostic tests can show results in as little as five minutes and up to 45 minutes. A positive molecular test shows an active case of COVID-19. A negative test may indicate that the person has already had COVID-19 and recovered, or that the person has not had it and may test positive in the future.
The serological, or blood, tests are newer point-of-care tests that use a drop of blood from a finger stick to determine antibodies in the bloodstream. These tests provide results in as little as ten minutes. Because the body must have an infection for some time before antibodies develop, a positive result may show that the person has already had the illness and has recovered. A negative test does not rule out infection, however; it may simply mean that the person has COVID-19 but simply has not had it long enough to develop antibodies. Serological test development is allowed under FDA policy, but does not require FDA review and authorization like molecular tests.
The well-being and emotional resilience of healthcare providers are critical components of maintaining essential healthcare services during the COVID-19 virus outbreak. Therefore, it is crucial to anticipate the stresses associated with this work and put in place supports for healthcare providers before burnout or PTSD develops.
The Nursing Care Quality Assurance Commission has shared a resource in Healthcare Compliance Northwest LLC, a group that is prepared to offer some complimentary crisis intervention stress debriefing. Crisis Intervention Stress Debriefing can help healthcare providers work through their feelings with the help of psychiatric practitioners who specialize in trauma and PTSD. If this is a resource that can be helpful for your facility, their team would greatly appreciate the opportunity to work with you. Visit their website for additional information.
The WHCA team has been available to help members with a number of questions and challenges throughout the current public health crisis affecting our region. We have developed a list of Frequently Asked Questions for both assisted living and skilled nursing providers, and we continue to add topics to keep members informed. You can review the FAQ AL v3 and the FAQ SNF v3 on the WHCA COVID-19 resource page .
In response to the immediate need to provide information regarding COVID-19 to caregivers, DSHS is offering blanket approval for the course, National COVID-Ready Caregiver Certification The course is free until April 17, 2020; after that date, the cost will be $39.
To access the training :
  1. Follow the link and click For Caregivers - Enroll Now. If the link does not work, copy and paste the URL address into a different browser, such as Google Chrome. (Click on lower white button as show in graphic above.)
  2. Enter the promo code WACOVIDCERT (the cost will change from $39 to free).
  3. Enter your email address and name; select a password to create an account. You will receive two emails from National COVID-Ready Certification Team: 1) Confirm your account – follow instructions to confirm your enrollment; and 2) You are now enrolled – follow link to access the course.

If you have difficulty accessing or navigating the course, please email NextStep.

Once learners successfully complete the training, they will be able to print the certificates directly from the NextStep website. Any student who presents a certificate of completion from NextStep may be issued a DSHS CE certificate for three hours . The certificate should include your printed name and signature, the name of the course and the approval code as shown above .
You do NOT need to apply to use it, nor have an approval letter. Please email David Chappell with any questions.

In addition, a Dear Provider letter issued April 7, 2020 , provides another educational tool that can be used in facilities. The program teaches infection control practices. The letter contains a link to the slides for it.
In response to questions from employers and their representatives, the Department of Labor & Industries has made certain policy decisions to provide some financial relief to state fund employers from the impact of allowed COVID-19 claims. These decisions are outlined in the “Frequently Asked Questions” (FAQ) document posted here . L&I also wants you to be aware of premium reporting requirements under certain circumstances such as when a business has been closed as a result of the pandemic, yet the employer is continuing to pay their workers. They’ve also clarified that injured workers whose temporary light duty ends are entitled to time-loss compensation. If you have any questions, please contact your loss control manager at Employer Resources NW, or your retrospective rating representative at Labor and Industries.
WHCA members have expressed concerns about required fire and life safety inspections, including sprinkler backflow checks. The concern is about the potential for asymptomatic transmission of COVID-19. Unfortunately, CMS has not waived deadlines or issued a blanket waiver for these mandatory inspections. As with vendors and essential health care personnel, providers must provide access to inspectors, and must conduct screening prior to admittance. We are working now to request a waiver of these standards and will keep you apprised about our progress.
A Dear Provider Letter issued April 7, 2020 , to assisted living facilities clarified that HIPAA requirements allow for facilities to submit census information on behalf of residents without their authorization. Submission of census data is required by law, and facility administrators now have an extension until June 19 to submit the data.
The Department of Health (DOH) is asking all healthcare facilities to implement personal protective equipment (PPE) conservation strategies to the greatest extent possible during this time. Click here for PPE conservation strategies provided by DOH. Questions regarding PPE conservation should be directed to the Washingto State DOH or your local health jurisdiction .
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.