Discussions continue with regulatory bodies including DSHS, DOH, and CMS regarding the need for clarification related to CMS’s release of QSO 20-39 and the conflicts with our Safe Start for LTC Plan (nursing homes and facilities for individuals with intellectual disabilities). Most other states have similar conflicts and AHCA continues to address the concerns with CMS on our behalf. As more information becomes available, WHCA will ensure you are made aware.
In the guidance, CMS states that at this time visitor testing is NOT required. However, they go on to encourage facilities in medium or high-positivity counties to test visitors, if feasible. If so, facilities should prioritize visitors that visit regularly (e.g., weekly), although any visitor can be tested. Facilities may also encourage visitors to be tested on their own prior to coming to the facility (e.g., within 2–3 days) with proof of negative test results and date of test.
This guidance is limited and poses additional questions regarding the feasibility of testing visitors for COVID. Keep in mind that all tests performed in the facility with point-of-care antigen devices require a MD/practitioner’s order and facility reporting.
Communal Dining and Activities
Another area where there is discrepancy between the CMS guidance and the more stringent WA LTC Reopening plan is communal dining and activities. The CMS guidance states that while adhering to the core principles of COVID-19 infection prevention, communal activities and dining may occur.
Residents may eat in the same room with social distancing (e.g., limited number of people at each table and with at least six feet between each person) and that facilities should consider additional limitations based on status of COVID-19 infections in the facility.
CMS also states that group activities may be facilitated (for residents who have fully recovered from COVID-19, and for those not in isolation for observation, or with suspected or confirmed COVID-19 status) with social distancing among residents, appropriate hand hygiene, and use of a face covering. Facilities may be able to offer a variety of activities while also taking necessary precautions with alterations to adhere to the guidelines for preventing transmission.
Please keep in mind, RCS and CMS Seattle have agreed that providers and regulators need additional time to digest the implications of CMS’s revision. Accordingly, because portions of Washington’s phased reopening/visitation plan are more stringent than CMS’s revisions, Washington SNF providers will continue to follow Washington’s phased reopening/visitation plan until RCS is able to provide further guidance.