COVID-19 Resources

In response to the coronavirus (COVID-19) pandemic, WHCA/WiCAL continues to work with the state and federal government​​​s to ensure nursing homes, assisted living communities, and intermediate care facilities for individuals with intellectual disabilities receive necessary supplies and guidance to prevent the spread ​of this virus.​

On April 16, U.S. Health and Human Services Secretary Xavier Becerra renewed the declaration that a public health emergency exists. This is effective April 16, 2022 and will continue for 90 days pursuant to federal law.

On Thursday, April 7, CMS issued QSO-22-15-NH & NLTC & LSC – Update to COVID-19 Emergency Declaration Waivers for Specific Providers. The memo announced that CMS is ending some (not all) COVID-related 1135 waivers, including federal waivers which allowed for the creation of Emergency and Temporary Nurse Aide Training Programs here in Wisconsin. These employment and training flexibilities will end 60 days from the publication of QSO-22-15-NH & NLTC & LSC (PDF).


Please note: CMS’s announcement of certain 1135-waiver end dates does not impact the 3-Day Stay or Spell of Illness waivers. Those waivers remain in place nationwide for all hospitals, communities, and SNFs. This week, the federal PHE was renewed for an additional 90-day period, thus the current expectation is that remaining 1135 waivers (those not announced to be scheduled to end, see below) will be in place at least through mid-July, unless CMS issues a new announcement related to rescinding other 1135 waivers not listed below.


CMS announced it will end specified waivers in two groups:

On Saturday, May 7, CMS will end 1135 waivers related to:

  • Resident Groups
  • Physician Delegation of Tasks in SNFs
  • Physician Visits
  • Physician Visits in Skilled Nursing Facilities/Nursing Facilities
  • Quality Assurance and Performance Improvement (QAPI)
  • Detailed Information Sharing for Discharge Planning for Long-Term Care (LTC) Facilities

On Monday, June 6, CMS will end 1135 waivers related to:

  • Physical Environment
  • Life Safety Code (LSC) and Health Care Facilities Code (HCFC) ITM
  • Outside Windows and Doors
  • Life Safety Code-Fire Drills & Temporary Construction
  • Paid Feeding Assistants for LTC facilities
  • in-Service Training for LTC facilities
  • Training and Certification of Nurse Aides for SNF/NFs
  • Clinical Records

Of all waivers to be rescinded either on May 7 or June 6, likely the most impactful will be the elimination of 1135 waivers which allowed Wisconsin the flexibility to create Emergency Nurse Aide and Temporary Nurse Aide programs. If you haven’t already, it is critical that providers using either or both of these 1135-related nurse aide programs begin a transition process for these staff members. See the below timeline, and begin planning now to ensure your facility is positioned to place as many of these caregivers as possible on the Registry before time runs out:

On or before May 7:

  • New Emergency Nurse Aide Training Programs must be approved prior to May 7 in order to begin a new training class of Emergency Nurse Aides.
  • No new ETP training classes will be approved after May 7.

On or before June 6:

  • Emergency Nurse Aide Training Programs must complete all training classes and submit checklists.
  • DQA will rescind all waivers for Emergency Nurse Aide Training Programs
    • Please note: this does not apply to traditional, 75+ hour training nurse aide training programs. Previously approved permanent training programs may continue to train at the hours for which they are approved.
  • The CMS-required 120-day period for all trained students to test and get on the Registry will be reinstated for both Emergency Nurse Aides and traditionally trained nurse aide students, meaning that Emergency Nurse Aides will have until October 4, 2022 to get on the Registry.
    • CMS has announced there will be a limited exception for those who are experiencing testing and/or training capacity issues and have received approval from their state official. It is not yet clear if Wisconsin DHS officials expect any significant testing/training capacity issues which may lead to an exception being granted.
  • Temporary nurse aides, not on a path to the Wisconsin Nurse Aide Registry, must stop working as nurse aides unless they are employed full time and enrolled in an approved permanent nurse aide training program.
    • Out-of-state certified nurse aides who are not on the Wisconsin Nurse Aide Registry are considered temporary aides.
    • If you currently are utilizing Temporary Nurse Aides, NOW is the time to discuss with them future opportunities by either 1) enrolling in the Emergency Nurse Aide program, or 2) enrolling in a traditional 75+ hour nurse aide training program!

After receiving member inquiries, WHCA/WiCAL reached out to DHS to seek clarification on whether CMS’s announcement of rescinding the 1135 nurse aide waivers would affect DHS’s recent approvals of some NATCEP 2-year prohibition waivers (which are separate from 1135 waivers). DHS has informed WHCA/WiCAL that at this time, DHS does not have any plans to rescind those two-year NATCEP prohibition waivers as a response to the rescission of 1135 waivers.

If you have additional questions about the implications on the upcoming rescission of the above listed 1135 waivers, please reach out to Director of Government Relations and Regulatory Affairs, Jim Stoa.

WHCA/WiCAL will continue to share additional information as it becomes available.

AHCA is seeking additional clarifications from CMS, and in the meantime has outlined key takeaways and next steps facilities can take to prepare for the upcoming end of the 1135 waiver (please note: AHCA’s use of ‘TNA’ is similar to Wisconsin’s Emergency Nurse Aide).

To learn more about starting a nurse aide training program, please visit the DHS Nurse Aide Training and Registry information webpage (link)

WHCA/WiCAL primarily shares COVID-19 updates through our newsletters. To view the archive of COVID-19 articles, please click HERE. To sign up to receive our communications (members only), please click HERE.

We will continue to provide resources to work through the pandemic. We are committed to delivering the most up-to-date information for both members and non-members as the situation continues to develop and will continue to update this webpage.

Skilled Nursing Facility Guidance

Skilled Nursing Facility Guidance

Quick Links:



Vaccine Mandate

CMS Vaccine Mandate

CMS issued QSO 22-07-ALL , which outlines the staff vaccination rules for skilled nursing facilities and that the surveyor training slides were available.

We’d like to highlight a few more details. The surveyor training indicates a phase in program for compliance. The ultimate expectation is 100% compliance with the vaccine mandate but indicates some flexibility in penalty implementation as follows:

  • Day 30 (1/27/22) – Day 59 – The facility is considered compliant if it demonstrates that all policies and procedures are developed and implemented and 100% of staff have received at least one dose of vaccine, or has a pending request for, or have been granted an exemption, or has a CDC-approved temporarily delayed vaccination.
    • If the facility demonstrates 80-90% the facility is considered non-compliant and will be cited using F-888. If the facility is above 80% and has a plan to achieve 100% vaccination rate within 60 days, they would not be subject to an enforcement action.
    • Facilities with less than 80% of staff who have received at least one dose of vaccine, or have a pending request for, or have been granted an exemption, or a temporary delayed vaccination, the facility is noncompliant and will be cited at F-888 and could be subject to additional enforcement actions.
  • Day 60 – Day 89 – Facilities are expected to be 100% compliant with the requirements.
    • If the facility has less than 100% compliance with the vaccine mandate, the facility is non-compliant
    • If the facility is above 90% and has a plan to achieve 100% vaccination within 30 days, they would not be subject to an enforcement action.
    • If the facility is less than 90%, they will be cited at F-888 and they could be subject to additional enforcement actions.
  • After 90 days – the following diagram shows how compliance will be calculated, Anything below 100% compliance will result in noncompliance and enforcement action.

Page 14 of the Attachment A of QSO 22-06-ALL  also identifies the survey process, the number of employee records to be reviewed (including staff and contract staff) and how scope and severity will be identified.

Additional Resources:


If you have any questions, please contact Rick AbramsPat Boyer, or Jim Stoa. Please be sure to contact WHCA/WiCAL immediately if you experience a significant exodus of employees due to the vaccine mandate and are experiencing a crisis staffing shortage.


Visitation

Visitation

CMS issued QSO-20-39-NH which issued new guidance for visitation in nursing homes during the COVID-19 public health emergency.

Facilities should accommodate and support indoor visitation, including visits for reasons beyond compassionate care situations, based on the following guidelines:

  1. There has been no new onset of COVID-19 cases in the last 14 days and the facility is not currently conducting outbreak testing;
  2. Visitors should be able to adhere to the core principles and staff should provide monitoring for those who may have difficulty adhering to core principles, such as children;
  3. Facilities should limit the number of visitors per resident at one time and limit the total number of visitors in the facility at one time (based on the size of the building and physical space). Facilities should consider scheduling visits for a specified length of time to help ensure all residents are able to receive visitors; and
  4. Facilities should limit movement in the facility. For example, visitors should not walk around different halls of the facility. Rather, they should go directly to the resident’s room or designated visitation area. Visits for residents who share a room should not be conducted in the resident’s room.

Click HERE to view “Facilitating Safe Visitation in Long Term Care Communities” by AHCA/NCAL.


Outdoor Visitation

Outdoor Visitation

Nursing Home Visitation – COVID-19, CMS Memo QSO-20-39 (PDF), has new guidance and expectations on how nursing homes can safely facilitate in-person visitation to address the psychosocial needs of residents. The memo covers information specific to outdoor visitation.

DHS strongly encourages facilities to implement the guidance below when providing outdoor visitation.

Facility criteria

  • Establish a schedule for visitation hours. Facilities should work with prospective visitors individually to schedule an appointment to visit a resident, and should discuss in advance the length of the appointment.
  • Have adequate staff present to allow for help with outdoor transition of residents, and to assist with cleaning and disinfecting any visitation areas as necessary.
  • Clean and disinfect the visitation area, including tables, chairs, and other shared surfaces between visits.
  • Clearly communicate and supervise each visit to ensure the use of face masks or cloth face coverings by visitors, and social distancing of six feet between residents and all visitors.
  • Staff should maintain visual observation but provide as much distance as necessary to allow for privacy of the visit conversation.
  • Have a system to ensure all visitors are prescreened for fever and any other symptoms of COVID-19 not more than 24 hours in advance. Ill visitors must not visit.
  • Have a system to screen visitors on arrival for fever and any other symptoms of COVID-19 at a screening location designated outside the building, and exclude those with these symptoms from visiting.
  • Have a system to ensure residents and visitors wear a face mask or other cloth face covering at all times, as tolerated.
  • Outdoor visitation may take place under a canopy or tent with not more than two walls.
  • Outdoor visitation spaces must be designed to be accessible without visitors having to walk through the facility.
  • Outdoor visitation spaces must ensure that a minimum distancing of at least 6 feet between the visitors and resident is achievable in the outdoor space when determining the maximum number of residents and visitors who can simultaneously occupy the outdoor space.
  • Provide alcohol-based hand sanitizer to people visiting residents and provide signage and verbal reminders of correct use.
  • Establish additional guidelines as needed and as determined by the facility to ensure the safety of visitations and their facility operations. These guidelines must be reasonable and must take into account the individual needs and wishes of residents.

Resident criteria

  • Current COVID-19 positive residents, residents with COVID-19 signs or symptoms, and residents in a quarantine or observation period due to their admission or re-admission status are not eligible for outside visits.
  • Residents who have had COVID-19 must no longer require transmission-based precautions as outlined by the CDC and DHS guidelines to be eligible for outside visits.
  • Residents must wear a mask (or other face covering to prevent spread of respiratory secretions when they are talking, sneezing, or coughing) at all times, as tolerated.

Visitor criteria

  • Visitors must wear a mask (or other face covering to prevent spread of respiratory secretions when they are talking, sneezing, or coughing) during the entire visit unless they are unable to do so for medical reasons.
  • Visitors must use alcohol-based hand sanitizer upon entering and exiting the visitation area.
  • Visitors must be prescreened and actively screened for fever and any other symptoms of COVID-19, and must attest to COVID-19 status if known. This should be done during prescreening and again upon arrival at a designated location outside the building. Any individual with symptoms of COVID-19 should be excluded from visitation.
  • Any gifts or packages for the resident should be dropped off with staff to give to the resident.
  • Visitors should not walk through the facility to get to the outdoor visitation area.
  • Visitors must sign in and provide contact information.
  • Due to the risk of exposure, holding hands, hugging, kissing, or other physical contact is not allowed during family visits. Physical distancing of six feet must be maintained for the duration of the visit.
    • Visitors under age 12 years must be in the control of adults who bring them and must also comply with physical distancing requirements. Visitors under age 12 years must wear a mask.
  • Pets must be under the control of the visitor bringing them.
  • Visitors must stay in designated visitation locations.

Weather

Visits should occur only on days when there are no weather warnings that would put either the visitor or resident at risk.

Facilities that meet the criteria above and elect to permit outdoor visits must make this option available to all residents unless they believe:

  1. Circumstances pose a risk of transmitting COVID-19 to the facility because the resident or visitor does not comply with infection prevention and control guidance, or
  2. The resident or visitor is at risk of abuse/harm.

Residents and their loved ones may contact providers with questions about outdoor visits. Facilities should ensure residents, and their loved ones, have access to the Ombudsman Program at the Board on Aging and Long Term Care at 800-815-0015.


Skilled Nursing Testing Requirements

Skilled Nursing Testing Requirements

The current testing guidance, which was published August 26, 2020, can be found here: QSO 20-38-NH Revised

The revised COVID-19 staff testing is based on the facility’s county level of community transmission instead of county test positivity rates, which can be found on the CDC COVID-19 Integrated County View website. The frequency of testing was also updated under the new guidance.

Under the new guidance, facilities now have two options to conduct outbreak testing:

  1. Through a contact tracing approach
  2. Through a broad-based testing approach

When prioritizing individuals to be tested, facilities should prioritize individuals with signs and symptoms of COVID-19 first, then perform testing triggered by an outbreak investigation (as specified below).

Table 1: Testing Summary

Testing Trigger Staff Residents
Symptomatic individual
identified
Staff, vaccinated and unvaccinated, with signs or symptoms must be tested Residents, vaccinated and unvaccinated, with signs or symptoms must be tested.
Newly identified COVID19 positive staff or
resident in a facility that
can identify close contacts
Test all staff, vaccinated and unvaccinated, that had a higher-risk exposure with a COVID-19 positive individual. Test all residents, vaccinated and unvaccinated, that had close contact with a COVID-19 positive individual.
Newly identified COVID19 positive staff or
resident in a facility that is
unable to identify close
contacts
Test all staff, vaccinated and unvaccinated, facility-wide or at a group level if staff are assigned to a specific location where the new case occurred (e.g., unit, floor, or other specific area(s) of the facility). Test all residents, vaccinated
and unvaccinated, facility-wide
or at a group level (e.g., unit,
floor, or other specific area(s) of
the facility).
Routine testing According to “Routing Testing Intervals by County COVID-19 Level of Community Transmission” table below Not generally recommended

Routine testing of unvaccinated staff should be based on the extent of the virus in the community. Fully vaccinated staff do not have to be routinely tested. Facilities should use their community transmission level as the trigger for staff testing frequency. Reports of COVID-19 level of community transmission are available on the CDC COVID-19 Integrated County website

Table 2: Routine Testing Intervals by County COVID-19 Level of Community Transmission

Level of COVID-19 Community
Transmission
Minimum Testing Frequency of
Unvaccinated Staff+
Low (blue) Not recommended
Moderate (yellow) Once a week*
Substantial (orange) Twice a week*
High (red) Twice a week*

+Vaccinated staff do not need to be routinely tested.
*This frequency presumes availability of Point of Care testing on-site at the nursing home or where off-site testing turnaround time is <48 hours

According to a news bulletin from the Department of Health Services, long-term care facilities, including both nursing homes and assisted living facilities, can request BinaxNOW tests through the federal government to help meet antigen testing needs. To begin a request for BinaxNOW tests, email HHSbinax@hhs.gov. U.S. Health and Human Services has indicated that their turnaround time on orders is two weeks.

Additionally, PCR test supplies are available to order through DHS at this time. The processing of PCR tests generally takes 2-3 days, though heightened demand may increase this timeframe.

DHS recently reported that they were notified in the late afternoon on Tuesday, January 11, by Abbott of its decision on January 7 to extend by three months after the expiration date for certain BinaxNow antigen rapid test kits that were first extended for six months in May 2021.

Please do not discard test kits that you may have that were scheduled to expire. Abbott has informed DHS that additional details will be provided next week to confirm specific test kit lot numbers that are affected by this extension and WHCA/WiCAL will continue to report on this.

Please reach out to WICOVIDTest@wisconsin.gov with any questions.


Reporting Requirements

Reporting Requirements

On May 6, 2020, CMS issued Interim Final Rule Updating Requirements for Notification of Confirmed and Suspected COVID-19 Cases Among Residents and Staff in Nursing Homes Memo, QSO-20-29-NH (PDF). This requires nursing homes to report COVID-19 facility data to the CDC and to residents, their representatives, and families of residents in facilities. The memo states that failure to report in accordance with 42 CFR § 483.80(g) can result in an enforcement action. CMS will begin posting data from the CDC National Healthcare Safety Network (NHSN) for viewing by facilities, stakeholders, or the public. The COVID-19 public use file will be available at COVID-19 Nursing Home Data. The memo includes updated COVID-19 focus survey forms and regulatory tags.

AHCA/NCAL recently released a resource on common National Healthcare Safety Network (NHSN) errors and how to avoid them. To reduce gaps in reporting, it is highly recommended to have at least two people with security access to the NHSN reporting pathways.

Please contact NHSN@CDC.gov with any additional questions.


EMResource

EMResource

The Wisconsin Department of Health Services (DHS) is strongly encouraging nursing homes to report the number of skilled nursing facility (SNF) beds available in their location each day to EMResource as part of a bed tracking system. With the daily reports from nursing homes, DHS hopes the “SNF bed tracker” will provide a real time picture of bed availability across the state, which hospitals can use as they work to identify potential post-acute care placements for their patients. In an EMResource Update , DHS wrote, “Reporting is optional, and strongly encouraged.” DHS has delivered the same message in its meetings with both nursing homes and hospitals.

The EMResource Bed Tracking System tracks bed availability, identifies the number of patients pending post-acute discharges, and provides a real-time picture of bed capacity in both hospitals and nursing homes across the state. The system, expanded in March 2021 to include a nursing home dashboard, has the ability to save hospitals and nursing homes many hours of searching for beds by phone and email.

DHS is asking area hospitals and nursing homes to work together to populate and use the SNF bed tracker as a resource. In March, DHS hosted a training webinar for nursing homes to introduce the tracker’s reporting capabilities. The webinar recording can be accessed HERE.

To request a user account for your facility, please send your name, facility and email address to DHSEMResource@dhs.wisconsin.gov.

We know that you are very busy but we ask that you make every effort to register with EMResource and report bed availability data at least weekly.


New Admissions, Transfers, and Discharges

New Admissions Transfers and Discharges

The Wisconsin Department of Health Services (DHS) is strongly encouraging nursing homes to report the number of skilled nursing facility (SNF) beds available in their location each day to EMResource as part of a bed tracking system. With the daily reports from nursing homes, DHS hopes the “SNF bed tracker” will provide a real time picture of bed availability across the state, which hospitals can use as they work to identify potential post-acute care placements for their patients.

The EMResource Bed Tracking System tracks bed availability, identifies the number of patients pending post-acute discharges, and provides a real-time picture of bed capacity in both hospitals and nursing homes across the state. The system, expanded in March 2021 to include a nursing home dashboard, has the ability to save hospitals and nursing homes many hours of searching for beds by phone and email. Forty percent of nursing homes are signed up and actively report in the system. DHS requests the remaining 60% to enroll in EMResource and consistently report into the bed tracker dashboard.

DHS is asking area hospitals and nursing homes to work together to populate and use the SNF bed tracker as a resource. In March, DHS hosted a training webinar for nursing homes to introduce the tracker’s reporting capabilities. The webinar recording can be accessed HERE.

To request a user account for your facility, please send your name, facility and email address to DHSEMResource@dhs.wisconsin.gov.


Survey/Enforcement

Survey/Enforcement

On January 4, 2021, CMS revised QSO-20-31-All: COVID-19 Survey Activities, CARES Act Funding, Enhanced Enforcement for Infection Control deficiencies, and Quality Improvement  Activities in Nursing Homes.

“Following the March 6, 2020 survey prioritization, CMS has relied on State Survey Agencies to perform Focused Infection Control surveys of nursing homes across the country. We are now initiating a performance-based funding requirement tied to the Coronavirus Aid, Relief and Economic Security (CARES) Act supplemental grants for State Survey Agencies. Further, we are providing guidance for the limited resumption of routine survey activities.

CMS has revised the criteria requiring states to conduct focused infection control surveys due to the increased availability of resources for the testing of residents and staff and factors related to the quality of care.

CMS is providing Frequently Asked Questions related to health, emergency preparedness and life safety code surveys

CMS is also enhancing the penalties for noncompliance with infection control to provide
greater accountability and consequence for failures to meet these basic requirements. This action follows the agency’s prior focus on equipping facilities with the tools they needed to ensure compliance, including 12 nursing home guidance documents, technical assistance webinars, weekly calls with nursing homes, and many other outreach efforts. The enhanced enforcement actions are more significant for nursing homes with a history of past infection control deficiencies, or that cause actual harm to residents or Immediate Jeopardy.”


Emergency Regulatory Waivers

Emergency Regulatory Waivers

CMS issued QSO-21-17-NH which ended the emergency blanket waivers related to notification of Resident Room or Roommate changes and Transfer and Discharge notification requirements.


Five-Star and Quality Ratings

Five-Star and Quality Ratings

CMS issued QSO-21-06-NH which announced that CMS would resume calculating nursing homes Health Inspection and Quality Measure ratings on January 27, 2021 and would be completing the transition to the new Care Compare website.

On January 7, 2022, CMS published QS0–22-08-NH , entitled “Nursing Home Staff Turnover and Weekend Staffing Levels.” This document reflects the changes that CMS will begin positing on the Care Compare website. These changes include:

  • Weekend Staffing
  • Staff Turnover

Weekend Nursing Staffing

CMS wrote in QSO 19-02-NH  that “due to concerns related to low staffing on weekends, in November 2018, CMS began identifying facilities with reported low weekend staffing to state agencies and requiring state agencies to conduct surveys in a portion of those facilities on weekends.”

Also, in August 2020, the OIG recommended that CMS should explore ways to provide consumers with additional information on daily staffing levels and how weekend staffing compares to other nursing homes.  In addition, the OIG noted the need to identify the impact of COVID-19 CMS report measures of nurse turnover as soon as possible in August 2021.

As a result of these recommendations, CMS will begin posting date on the level of weekend RN and total nurse on the Care Compare website in January 2022.  This information will also be added to the Nursing Home Five Star Quality Rating System in July 2022 

Nursing Home Staff Turnover

The relationship between staffing turnover and quality is also being reviewed. CMS plans to post the following measures on staff turnover in January 2022 including:

  • The percent of RN staff that left the facility over the last year
  • The percent of total nurse staff that have left the facility over the last year
  • The number of administrators that have left the facility over the last year.

CMS will include these measures in the Staffing Domain of the Five Star Rating System Technical Users’ Guide on January 14, 2022, This information is being posted for stakeholders to conduct their own analysis. The employee-level data will be posted in the Payroll Based Journal (PBJ). This data will also be posted on the Provider Data Catalogue, in the section for “Nursing Homes including rehab services”

It’s important that you read and understand which data points work in each of the two new categories. Many providers attended training when the PBJ process first started, however, does your present facility staff understand the importance of this data and do you have systems in place to validate the data prior to submission.

For questions or more information please contact Pat Boyer at pat@whcawical.org, Jim Stoa at jstoa@whcawical.org, or Rick Abrams at rick@whcawical.org.


On-Site Hair Salon and Barber Services

On-Site Hair Salon and Barber Services

DHS recommends facilities that provide on-site cosmetology services follow the guidance below regarding screening, hand hygiene, face masks, social distancing, cleaning and disinfecting work areas and equipment, use of PPE, and implementation of an auditing system for compliance with facility policies and procedures for safe salon services.

Policies, Procedures, and Supplies

The facility should:

  • Develop and follow facility policies and procedures that incorporate CDC guidance regarding cleaning and disinfection protocols, as well as employee screening.
  • Develop and implement procedures that address infection control measures and the management of safe salon services.
  • Implement an ongoing facility auditing system to check for compliance with the facility’s policies and procedures for safe salon services.
  • Limit contact of the cosmetologist with other residents and staff as much as possible. This may be accomplished by having a separate area for salon services close to the entrance of the facility, but is not required. Try to develop a path that avoids walking through resident care areas.
  • Have an adequate supply of PPE and essential cleaning and disinfection supplies for facility staff and cosmetologists.
  • Develop a process for cleaning cosmetology equipment such as scissors, combs, and brushes.
  • Have adequate resident care staff.

Licensed Cosmetologist Services

The cosmetologist should:

  • Receive COVID-19 infection control training from the facility.
  • Test negative for COVID-19 prior to resuming services in the facility, and participate in any ongoing routine staff testing guidance followed by the facility.
  • Be screened for signs and symptoms of illness before each visit, including all signs or symptoms of COVID-19 (cough, fever or chills, diarrhea, a new loss of taste or smell, close contact with someone with COVID-19 during the prior 14 days, undergoing evaluation for COVID-19 such as a pending viral test, shortness of breath, difficulty breathing or any other respiratory symptoms). Also, verify that they have had no contact with individuals with suspected or confirmed COVID-19.
  • Practice hand hygiene before and after contact with residents. Use of alcohol-based hand rub is preferred, but soap and water for at least 20 seconds can also be performed.
  • Wear a well-fitted facemask (procedure or surgical mask) upon entry to the facility.
  • Wear facility-designated and provided PPE, including eye protection and a well-fitted facemask (procedure or surgical mask) when delivering hair salon services.
  • Resident capes should be changed between residents and laundered before being used again.
  • Be trained to self-monitor after each visit and report any symptoms of COVID-19 to the facility promptly, as well as health care providers and the local/tribal public health department.
  • Sign a statement attesting that he or she will follow all facility policies and procedures regarding salon and barber services to ensure facility safety.
  • Clean and disinfect the area and equipment between resident appointments using products on the EPA List N Disinfectants for Coronavirus shown to be effective against the SARS-CoV-2 virus

The cosmetologist should not dry hair using a hand held hair dryer.

The facility should:

  • Verify that the resident is well with no signs or symptoms of COVID-19 (cough, fever or chills, diarrhea, a new loss of taste or smell, close contact with someone with COVID-19 during the prior 14 days, undergoing evaluation for COVID-19 such as a pending viral test, shortness of breath, difficulty breathing or any other respiratory symptoms, difficulty breathing or any other respiratory symptoms) before coming to their appointment.
  • Ensure that each appointment is prescheduled. Walk-ins should not be allowed.
  • Keep a record of the name of each resident client and the time and date of each salon visit.
  • Ensure that residents maintain social distancing of at least six feet between persons inside the salon and in any waiting area.
  • Ensure that each resident wash or sanitize their hands before entering or leaving the salon.
  • Ensure that each resident wears a face covering (preferably a face mask rather than a cloth face covering) at all times while in transit to and from the salon and while in the salon, including during washing, cutting, perming, and coloring.
  • Clean and disinfect the salon at the end of the day using products on the EPA List N Disinfectants for Coronavirus(link is external) shown to be effective against the SARS-CoV-2 virus

Facilities will need to determine whether they can follow these guidelines to ensure they can provide salon and barber services safely. This may not be a safe option for all facilities due to the availability of PPE, staffing patterns, and facility layout and/or location as outlined in the above guidance.


SNF Workforce

Workforce

Attention: nursing home providers who are currently under a two-year Nurse Aide Training and Competency Evaluation Program (NATCEP) prohibition – there is a new opportunity for you to receive a temporary waiver from the two-year prohibition, potentially allowing your facility to serve as a site for training. Please note: as with the traditional NATCEP prohibition waiver, a granted waiver would allow a nurse aide training program to be held in, but not by, a nursing facility within that two-year period.

In light of the staffing crisis and due to the continued public health emergency and 1135 waivers, DHS has determined to temporarily approve waiver requests which may not have been approved in the past due to the criteria outlined in DHS 129. This can only be accomplished by waiving certain portions of DHS 129. DHS has created a quick survey for requesters to complete which we will consider the request for the additional waivers. Please see the language below from the survey for the waiver details. The waiver request survey is available here: Nurse Aide Training Prohibition Waiver Requests.

DHS did send emails to several facilities who have recently had their waiver requests denied, sharing this information so that those providers can re-submit their waiver requests through this new process. If you did not get the email, and your facility is under a two-year, prohibition, you can still complete the survey linked above to be considered for a temporary waiver of the prohibition.

From the waiver request survey:

Due to the public health emergency and worsening staffing crisis as a result of the pandemic, DHS is temporarily allowing waiver approval for nurse aide training prohibitions to allow training in and not by the facility, which may not have been approved prior to the pandemic based on the criteria set forth in DHS 129.04(3)(a-f). Once the public health emergency has been lifted this allowance will no longer be considered and the criteria included in DHS 129.04(3)(a-f) will be followed.

By submitting this survey, you are requesting a waiver of DHS 129.04(3)(a-d,f) to allow nurse aide training in but not by a facility that is under nurse aide training prohibition. DHS129.04(3)(e) is a federal regulation that cannot be waived.

Waiver requests are approved with the following conditions:

  • Nurse aide training must be provided by a third party unrelated to the facility that is under nurse aide training prohibition. You must submit a signed document from the third party agreeing to provide the training or to use the facility as a clinical site. 
  • Any additional events that result in new nurse aide training prohibitions would require you to complete the survey again to request a separate waiver.
Assisted Living Facility Guidance

Assisted Living Facility Guidance

Quick Links


Assisted Living Facility Visitation

Assisted Living Facility Visitation

Background

With the onset of COVID-19 in our state, assisted living facilities have worked creatively to provide a living environment for residents that is as homelike as possible and least restrictive of each resident’s rights and freedoms. Each facility continues to be responsible for ensuring that care and services are provided in a manner that protects the rights and dignity of each resident. This includes ensuring residents maintain the right to have visitors according to their individual needs and wishes. Facilities should work together with residents and their families and loved ones to accommodate visitation.

Updated State and Federal Guidance

Recently, the Centers for Disease Control and Prevention (CDC) released new visitation guidance that promotes in-person and extended visitation for persons living in long-term care settings(link is external). This new information has been incorporated into the current Safer Visits in Assisted Living Facilities guidance to provide a balance between maintaining safety and supporting residents, family members and staff.

Part of these changes come with the Emergency Use Authorization from the Food and Drug Administration of COVID-19 vaccines. Millions of vaccinations have been administered to long-term care facility residents and staff. These vaccines have been shown to help prevent symptomatic COVID-19. However, visitors should not be required to show proof of testing or vaccination as a condition of visiting.

Revised Safer Visitation Guidance in Assisted Living Facilities: Guiding Principles

Facilities shall expand compassionate care visits already allowed to now support indoor visitation for all residents, regardless of vaccination status, except for a few circumstances when visitation should be limited due to a high risk of COVID-19 transmission. Compassionate care visits shall be permitted at all times.

Facilities should limit indoor visitation for:

  • Unvaccinated residents if the facility’s COVID-19 county positivity rate is greater than 10% and less than 70% of residents in the facility are fully vaccinated;
  • Residents with confirmed COVID-19 infection, whether vaccinated or unvaccinated until they have met the criteria to discontinue Transmission-Based Precautions; or
  • Residents in quarantine, whether vaccinated or unvaccinated, until they have met criteria for release from quarantine.

If there is not an outbreak in the facility, or if the outbreak is limited to a single unit, floor, or wing, the facility shall allow visitation to an unaffected unit, or within a wing or floor where an outbreak was identified if the outbreak is contained, and interventions are in place for continued containment.

Facilities should regularly monitor local disease activity as a consideration when implementing heightened visitation practices, but these should not be the sole factor in determining whether visits can occur. Resources for monitoring local disease activity levels include:

Additional factors to consider when implementing visitation practices:

  • Screen all who enter the facility for all signs and symptoms of COVID-19 (e.g., temperature checks, questions or observations about signs or symptoms, close contact to someone with COVID-19 during the past 14 days, undergoing evaluation for COVID-19, such as a pending viral test due to exposure or close contact to a person with COVID-19), and deny entry of those with any signs or symptoms.
  • Educate visitors and residents to perform hand hygiene before and after visits (use of alcohol-based hand rub is preferred).
  • Monitor that visitors wear a well-fitting face covering or mask (covering mouth and nose) unless contraindicated. If there are barriers to masking, such as a medical reason, alternatives will be discussed with resident visitors and an individualized, alternate plan will be implemented that is acceptable to the facility and the visitor.
  • Communicate distancing expectations. Physical distancing is preferred, however updated CDC guidance now indicates that a fully vaccinated resident may have physical contact with visitors, including hugging and holding hands. If the resident is fully vaccinated, they can choose to have close contact (including touch) with their visitor while wearing a well-fitting face mask and performing hand-hygiene before and after contact. Visitors should continue to physically distance from all other residents and staff in the facility.
  • Post instructional signage throughout the facility and provide proper visitor education on COVID-19 signs and symptoms, infection control precautions, other applicable facility practices (e.g., use of face covering or mask, specified entries, exits and routes to designated areas, hand hygiene).
  • Clean and disinfect high touch surfaces in the facility often, and designated visitation areas after each visit, including a resident’s room or apartment.
  • Ensure appropriate staff use of Personal Protective Equipment (PPE).
  • Perform effective cohorting of residents as needed (e.g., separate areas dedicated COVID-19 care).
  • Conduct resident and staff testing conducted as recommended.

Administrative Controls

As often as possible, resident visits should be scheduled for times that are desired by or convenient to the resident. This should include accommodating visits during evening, weekend, and holiday hours.

Facilities should enable visits to be conducted with a careful consideration for privacy. It is not necessary to monitor each visit on a 1:1 basis. Visitors who are unable to adhere to the core principles of COVID-19 infection prevention should not be permitted to visit or should be asked to leave. The facility should document the occurrence as you would any other event and include sufficient information to explain why the visitor was not permitted to visit and was asked to leave.

Facilities may consider noting the maximum number of visitors in the setting at any one time, in order to manage screening and best infection control practices. The length of the visit should be determined according to the needs of the resident.

Visitors should be instructed about how to summon staff in case of emergency or if they have questions or observations to share to avoid moving through the building randomly.

The facility’s policy should specify clear direction for a resident’s wishes and needs regarding visitation as noted in the resident’s ISP (Individual Service Plan) or care plan.

The facility’s visitation policy should address how the facility will handle visitors who do not comply with the facility’s infection control and safe visitation policies.

Facilities must remain alert and temporarily stop all inside visitation based on local or tribal public health advisement, the facility’s internal COVID-19 status, availability of PPE, or any other facility needs. Residents and visitors should be promptly informed of the need to temporarily stop visits, as well as the plan for mitigating increased risk and resuming visits.

The facility should consider designating a staff member to serve as the primary source of information, to receive concerns and to provide consistent communication.

Social Programs

While adhering to the Guiding Principles of COVID-19 infection prevention, communal activities and dining may occur. Residents may eat in the same room with physical distancing, limiting the number of people at each table and with at least six feet between each person. Facilities should consider additional limitations based on the status of COVID-19 infections in the facility.

Group activities may also be facilitated for residents who have fully recovered from COVID-19, and for residents not in isolation or quarantine for suspected or confirmed COVID-19. These activities should include social distance among residents, appropriate hand hygiene, and use of a face covering (except while eating). Facilities are able to offer a variety of activities while also taking necessary precautions. For example, book clubs, crafts, movies, exercise, and bingo are all activities that can be provided with alterations to adhere to the guidelines for preventing transmission, particularly when provided in small group settings.


Assisted Living Testing Requirements

Assisted Living Testing Requirements

The Wisconsin Department of Health Services (DHS) has updated Assisted Living COVID-19 Testing Guidance. The guidance was changed to be similar to the testing strategy used in a nursing home. Within the testing guidance you will find several other resources such as:

  • Who to test
  • When to test
  • The collection of samples
  • Reporting requirements
  • Links to apply for a CLIA Certificate/Waiver
  • Testing recommendations
  • Outbreak management and many more

Testing Supplies
Ordering of testing supplies based on your level of community transmission can be placed through the ordering website.

Community Transmission Routine Testing Frequency:
Low (blue), testing not recommended
Moderate (yellow), test once a week*
Substantial (orange), test twice a week*
High (red), test twice a week*
*Vaccinated staff do not need to be routinely tested

If you are using BinaxNow rapid antigen tests, results must be reported according to State and Federal requirements. See Reporting Guidance Document for information on how to report your results.

Questions
If you have questions regarding this information, please contact the COVID Testing Task Force at WICovidTest@wi.gov.

According to a news bulletin from the Department of Health Services, long-term care facilities, including both nursing homes and assisted living facilities, can request BinaxNOW tests through the federal government to help meet antigen testing needs. To begin a request for BinaxNOW tests, email HHSbinax@hhs.gov. U.S. Health and Human Services has indicated that their turnaround time on orders is two weeks.

Additionally, PCR test supplies are available to order through DHS at this time. The processing of PCR tests generally takes 2-3 days, though heightened demand may increase this timeframe.

DHS recently reported that they were notified in the late afternoon on Tuesday, January 11, by Abbott of its decision on January 7 to extend by three months after the expiration date for certain BinaxNow antigen rapid test kits that were first extended for six months in May 2021.

Please do not discard test kits that you may have that were scheduled to expire. Abbott has informed DHS that additional details will be provided next week to confirm specific test kit lot numbers that are affected by this extension and WHCA/WiCAL will continue to report on this.

Please reach out to WICOVIDTest@wisconsin.gov with any questions.


Waivers and Variances

Waivers and Variances

DHS is considering individual variances. Please see below for variance forms. Please submit each completed request form to the Bureau of Assisted Living Regional Office in which your facility is located.


Admissions and Discharges

Admissions and Discharges

Assisted living facilities may admit any individuals that they would normally admit to their facility, including individuals from hospitals where a case of COVID-19 was or is present. Facilities should follow the CDC guidance for infection control when COVID-19 is identified or suspected in a resident found in Discontinuation of Transmission-Based Precautions and Disposition of Patients with COVID-19 in Healthcare Settings (Interim Guidance).

If facilities admit or retain multiple residents diagnosed with COVID-19, they should consider the possibility of a dedicated wing or unit.

Facilities should create a plan for managing new admissions and readmissions whose COVID-19 status is unknown. Options include placement in a single room or in a separate observation area so the resident can be monitored for evidence of COVID-19.

Testing residents upon admission could identify those who are infected but otherwise without symptoms and might help direct placement of asymptomatic residents into a designated COVID-19 area in the facility. However, a single negative test upon admission does not mean that the resident was not exposed or will not become infected in the future. Newly admitted or readmitted residents should still be quarantined for evidence of COVID-19 for 14 days after admission and cared for using all recommended COVID-19 PPE. However, quarantine is no longer recommended for residents who are being admitted or readmitted to a post-acute care facility if the resident is fully vaccinated and has not had prolonged close contact with someone with SARS-CoV-2 infection in the prior 14 days. Close contact is defined as contact within six feet for 15 minutes or more in a 24-hour period.

Discharge

If a resident has been exposed and is being discharged, the resident requires quarantine at the receiving facility. However, quarantine is no longer recommended for residents who are being admitted or readmitted to a post-acute care facility if the resident is fully vaccinated and has not had prolonged close contact with someone with SARS-CoV-2 infection in the prior 14 days. Close contact is defined as contact within six feet for 15 minutes or more in a 24-hour period.

Therefore, you must inform the facility that is accepting the resident. If the facility is unable to meet transmission-based precautions and quarantine for the appropriate length of time, then the resident cannot be transferred.

Facilities must follow all regulations related to discharges, including involuntary discharges. A diagnosis of COVID-19 in and of itself does not meet the regulatory standard for an involuntary discharge.

Guidance from the State Disaster Medical Advisory Committee

Assisted living providers may benefit from reviewing the following memos that were prepared by the State Disaster Medical Advisory Committee (SDMAC) to provide recommendations to nursing homes and hospitals regarding the transfer, discharge and management of patients from hospitals to nursing homes. The purpose of the SDMAC is to advise the DHS Secretary regarding medical ethics during a declared disaster or public health emergency and to recommend policy relating to the equitable and fair delivery of medical services to those who need them under resource-constrained conditions.


On-Site Hair Salon and Barber Services

On-Site Hair Salon and Barber Services

DHS recommends facilities that provide on-site cosmetology services follow the guidance below regarding screening, hand hygiene, face masks, social distancing, cleaning and disinfecting work areas and equipment, use of PPE, and implementation of an auditing system for compliance with facility policies and procedures for safe salon services.

Policies, Procedures, and Supplies

The facility should:

  • Develop and follow facility policies and procedures that incorporate CDC guidance regarding cleaning and disinfection protocols, as well as employee screening.
  • Develop and implement procedures that address infection control measures and the management of safe salon services.
  • Implement an ongoing facility auditing system to check for compliance with the facility’s policies and procedures for safe salon services.
  • Limit contact of the cosmetologist with other residents and staff as much as possible. This may be accomplished by having a separate area for salon services close to the entrance of the facility, but is not required. Try to develop a path that avoids walking through resident care areas.
  • Have an adequate supply of PPE and essential cleaning and disinfection supplies for facility staff and cosmetologists.
  • Develop a process for cleaning cosmetology equipment (for example: scissors, combs, and brushes).
  • Have adequate resident care staff.

Licensed Cosmetologist Services

The cosmetologist should:

  • Receive COVID-19 infection control training from the facility.
  • Test negative for COVID-19 prior to resuming services in the facility, and participate in any ongoing routine staff testing guidance followed by the facility.
  • Be screened for signs and symptoms of illness before each visit, including all signs or symptoms of COVID-19 (cough, fever or chills, diarrhea, a new loss of taste or smell, close contact with someone with COVID-19 during the prior 14 days, undergoing evaluation for COVID-19 such as a pending viral test, shortness of breath, difficulty breathing or any other respiratory symptoms). Also, verify that they have had no contact with individuals with suspected or confirmed COVID-19.
  • Practice hand hygiene before and after contact with residents. Use of alcohol-based hand rub is preferred, but soap and water for at least 20 seconds can also be performed.
  • Wear a well-fitted facemask (procedure or surgical mask) upon entry to the facility.
  • Wear facility-designated and provided PPE, including eye protection and a well-fitted facemask (procedure or surgical mask) when delivering hair salon services.
  • Resident capes should be changed between residents and laundered before being used again.
  • Be trained to self-monitor after each visit and report any symptoms of COVID-19 to the facility promptly, as well as health care providers and the local/tribal public health department.
  • Sign a statement attesting that he or she will follow all facility policies and procedures regarding salon and barber services to ensure facility safety.
  • Clean and disinfect the area and equipment between resident appointments using products on the EPA List N Disinfectants for Coronavirus shown to be effective against the SARS-CoV-2 virus.

The cosmetologist should not dry hair using a hand held hair dryer.

The facility should:

  • Verify that the resident is well with no signs or symptoms of COVID-19 (cough, fever or chills, diarrhea, a new loss of taste or smell, close contact with someone with COVID-19 during the prior 14 days, undergoing evaluation for COVID-19 such as a pending viral test, shortness of breath, difficulty breathing or any other respiratory symptoms, difficulty breathing or any other respiratory symptoms) before coming to their appointment.
  • Ensure that each appointment is prescheduled. Walk-ins should not be allowed.
  • Keep a record of the name of each resident client and the time and date of each salon visit.
  • Ensure that residents maintain social distancing of at least six feet between persons inside the salon and in any waiting area.
  • Ensure that each resident wash or sanitize their hands before entering or leaving the salon.
  • Ensure that each resident wears a face covering (preferably a face mask rather than a cloth face covering) at all times while in transit to and from the salon and while in the salon, including during washing, cutting, perming, and coloring.
  • Clean and disinfect the salon at the end of the day using products on the EPA List N Disinfectants for Coronavirus shown to be effective against the SARS-CoV-2 virus

Facilities will need to determine whether they can follow these guidelines to ensure they can provide salon and barber services safely. This may not be a safe option for all facilities due to the availability of PPE, staffing patterns, and facility layout and/or location as outlined in the above guidance.

Vaccines

Vaccines

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Vaccine Mandate

Vaccine Mandate

CMS Interim Final Rule

​​The U.S. Supreme Court has stayed the preliminary injunctions against enforcement of the Centers for Medicare and Medicaid Services (CMS) interim final rule. This means CMS can enforce its vaccine mandate in states previously exempted due to the stay, with the exception of Texas.

CMS has released two QSO memos with separate deadlines for implementation. All other provisions are the same.

  • The December 28, 2021 QSO Memo  applies to California, Colorado, Connecticut, Delaware, District of Columbia, Florida, Hawaii, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, New Mexico, New York, North Carolina, Oregon, Pennsylvania, Rhode Island, Tennessee, Vermont, Virginia, Washington and Wisconsin.
  • The January 15, 2022 QSO Memo  applies to providers in the following states: Alabama, Alaska, Arizona, Arkansas, Georgia, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Mississippi, Missouri, Montana, Nebraska, New Hampshire, North Dakota, Ohio, Oklahoma, South Carolina, South Dakota, Utah, West Virginia and Wyoming.

*Important note: The guidance in this enforcement does not apply to Texas as of January 17, 2022.

CMS establishes the same requirements in both memos but offers separate compliance deadlines starting 30 days from the issuance of either memo. AHCA/NCAL has highlighted key points below, but providers in the above states are strongly encouraged to review the applicable QSO memo in full.

Long-term care facilities are able to track weekly COVID-19 vaccination data for residents and healthcare personnel through NHSN. For more information, please click HERE.

KEY HIGHLIGHTS

Which staff fall under the rule? 

Staff refers to all individuals providing any care or services for the facility and its residents, whether under contract or arrangement. The only individuals this does not apply to are individuals who telework full time or who provide services entirely remotely.

When are facilities in the states listed above required to be in compliance?

CMS implementation will be phased in as follows, depending on state. See map above and list to determine which applies for your facility.

  • January 27 or February 14, 2022 for the first dose for two dose regime (i.e., mRNA Pfizer or Moderna) or J&J if electing to receive the J&J, which includes:
    • Policies and procedures developed and implemented (template policies and procedures  are available on the AHCA/NCAL COVID-19 website under ‘Vaccines’).
    • 100 percent of staff having received one dose of vaccine, except those with or pending an exemption request and those having a temporary delay recommended by the CDC.
    • A facility above 80 percent and has a plan to achieve a 100 percent staff vaccination rate within 60 days would not be subject to enforcement action (e.g., civil monetary penalties [CMPs]).
  • February 28 or March 15, 2022 for the second dose for two dose regime, which includes:
    • ​Policies and procedures developed and implemented.
    • 100 percent of staff having completed the vaccine series, except those with granted exemption request and those having a temporary delay recommended by the CDC.
    • A facility above 90 percent and has a plan to achieve a 100 percent staff vaccination rate within 30 days would not be subject to enforcement action (e.g., CMPs).

How will compliance be determined?

Compliance will be determined through the regular survey process, including through standard and complaint visits and vaccination rates will be calculated from facility records and will take exemptions into consideration. Facilities are expected to track vaccination status, including booster status for each staff person and any exemptions, using a tracking tool of their choice. A facility’s tracking mechanism should clearly identify each staff member’s role, assigned work area, and how they interact with residents. Survey teams will also ask for information on how unvaccinated staff are assigned and additional precautions taken to prevent transmission. CMS will provide a specific tool for facilities to use at the time of the survey.

How will citations, including scope and severity, be determined?

Facilities found out of compliance (less 100 percent of staff vaccinated, not including those with valid exemptions) will receive a citation with scope and severity based on staff vaccination rates, number of COVID-19 cases, policy and procedure implementation, and infection control practices.

In the QSO memo , CMS provides detailed guidance on scope and severity and a scope and severity grid on page 14.

CMS also recently held a training for long-term care surveyors on enforcement of the vaccination rule. To view the slides and notes from the webinar, please click HERE .

Do unvaccinated staff need to follow any special precautions?

Yes, staff who are not yet fully vaccinated regardless of the reason must adhere to additional precautions that are intended to mitigate the spread of COVID-19. There are a variety of actions or job modifications a facility can implement to potentially reduce the risk of COVID-19 transmission including but not limited to:

  • ​Reassign unvaccinated staff to non-patient areas and duties.
  • Require staff who have not completed their primary vaccination series to follow additional CDC-recommended precautions, such as adhering to universal source control and physical distancing measures even if the facility is located in a county with low-to-moderate community COVID transmission. Although OSHA’s vaccine mandate is not in effect, there are additional  OSHA-required measures which should also be followed.
  • Require at least weekly testing.
  • Require use of a NIOSH-approved N95 or equivalent or higher-level respirator for source control, regardless of whether they are providing direct care to or otherwise interacting with patients.

AHCA/NCAL interprets this to mean providers must follow at least one of these stated precautions, or at least one other reasonable precaution not stated on this list. However, they are seeking clarity from CMS on whether this interpretation is correct and will communicate the response with members. This language is the same language CMS uses for other providers (e.g., hospitals) that are covered by this regulation.


OSHA

The U.S. Supreme Court on January 13, 2022 issued opinions in the Centers for Medicare and Medicaid Services (CMS) and Occupational Safety and Health Administration (OSHA) vaccination requirement cases and ruled that OSHA does not have the authority to mandate vaccines for large employers, and thus the OSHA vaccine mandate for large employers cannot be enforced.

What This Means for Long-Term Care Providers:

Assisted living providers are not included in the CMS IFR and are now not subject to a federal vaccine/testing requirement.


COVID-19 Booster Shots

COVID-19 Booster Shots

Following Emergency Use Authorizations from the Food and Drug Administration this week, the Centers for Disease Control and Prevention (CDC) provided updated recommendations for COVID-19 booster shots.

COVID-19 booster shots are now recommended for the following groups of individuals who received a Pfizer-BioNTech or Moderna COVID-19 vaccine, at 6 months or more after their initial series:​

Additionally, for those that are 18 and older that received the Johnson & Johnson COVID-19 vaccine two or more months ago, a booster shot is recommended.

Eligible individuals can get a booster shot of a different brand if they choose to do so as the CDC is now allowing for mixing and matching product for the booster shot. 

The CDC has created a webpage to help long term care providers access the booster dose. Providers should work with their long term care pharmacies to gain access to the booster dose. If you are having trouble accessing the vaccine, please contact your state or local health department’s immunization program. The appropriate contact for each immunization program can be found here .

As a reminder, the CDC has noted that the COVID-19 vaccine and the influenza vaccinations can be coadministered in cases where an individual is eligible for both vaccinations.

Many ALFs have partnered with pharmacies, or other vaccinators, for booster vaccinations; however, some ALFs may need assistance finding a pharmacy that would either vaccinate at the facility or at the pharmacy. DHS has partnered with the Pharmacy Society of Wisconsin (PSW) to help you find a nearby pharmacy to host a vaccination clinic at your ALF.

If you would like assistance partnering with a pharmacy, please contact PSW staff member Erica Martin at emartin@pswi.org. Erica will introduce you to a pharmacy that will vaccinate the ALF staff and/or residents at your facility. The ALF and pharmacy will be responsible for determining the amount of vaccine needed and the clinic date. The pharmacy will conduct the scheduled clinics and report the data to the Wisconsin Immunization Registry (WIR).

If you have questions or would like more information, please contact Erica Martin at emartin@pswi.org.


Care Compare

Care Compare

CMS unveiled functionality on Care Compare to enable users to compare staff and resident vaccination rates across different SNFs. This is to increase transparency and enable members of the public to easily access this information. State and national vaccination rates will also be displayed. The data will be updated every two weeks and comes from data reported by SNFs through the CDC’s National Healthcare Safety Network system.


#GetVaccinated

#GetVaccinated

AHCA/NCAL’s #GetVaccinated campaign encourages long term care staff and residents to get the COVID-19 vaccine. Providers and state affiliates may use the materials below to help communicate about the importance of vaccination as well as highlight progress. This digital toolkit includes a checklist of ideas, template letters to use with stakeholders, sample social media, and media prep material. Keep checking back for additional resources!

Click HERE for more information.

Workforce and Staffing Resources

Workforce and Staffing Resources

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DHS Agency Staffing Resource Assistance

DHS Agency Staffing Resource Assistance

Beginning on Monday, October 4, 2021, DHS began offering facilities supplemental temporary agency staffing. DHS has established a new process to request staffing services to assist with managing a facility’s staffing shortage this year.

Last week, we published these nine things you need to know, reproduced below. Additional information since last week’s publication are also included below the original nine things to know:

  1. Acute care, skilled nursing, long term care and assisted living facilities are eligible to receive staffing assistance;
  2. DHS has contracted with four staffing agencies;
  3. There are not separate contracts for each type of eligible health care facility. Therefore, the same contract will apply to hospitals, nursing facilities, assisted living, etc.;
  4. Given the limited surge staffing resources, DHS will prioritize requests to focus on the state’s staffing shortage “hot spots”. Immediately, those “hot spots” are where the COVID variant is surging and where there is a large back up of hospital patients ready for transfer (Health Emergency Readiness Coalition (HERC) region 4 and in the Fox Valley);
  5. While DHS expects a facility to have taken some internal and external actions to obtain additional staff, the staffing agency contract is its own process. For example, if a facility has only done an internal crisis staffing plan and has not attempted the WEAVR or RAST processes, this will not summarily disqualify the facility from obtaining staffing assistance. However very important: On the Facility Eligibility for Services Questionnaire, a facility must show that it has made some effort to acquire additional staff before applying for assistance through the staffing agency contract;
  6. The staffing agency contracts contain specific pricing for each category of employee. The agency must honor this pricing;
  7. DHS will pay 60% of the cost of the surge staffing and the facility will pay 40% of the cost;
  8. The contract does not contain a provision that prohibits a facility employee from leaving to work for the staffing agency. DHS believes that the likelihood of “employee poaching” is minimal. However very important: Please contact WHCA/WiCAL immediately if you believe that poaching has occurred with one or more of your employees;
  9. Surge staff arriving to work at your facility must abide by the facility’s rules and regulations. For example, if your facility requires that all employees are vaccinated against COVID, then the temporary employee must also be vaccinated.

Additional information:

  • If a facility is initially denied for not demonstrating adequate workforce shortage mitigation efforts, the facility can reapply to the program with new information to help demonstrate their need and that they have taken steps to mitigate the workforce challenges.
  • There is no provision in the DHS Contract or Work Order Agreement that would prohibit a facility from hiring a former temporary contracted agency staff as a permanent employee of the facility, but those agency staff have likely agreed to a waiting period in their contracts before they would be able to accept such a position – as is typical in staffing agency contracts with workers.
  • DHS advised that the typical duration of the work order will be 8 weeks or perhaps 90 days. Initial reports indicate that for some providers, the work order duration may even be longer than 90 days based on need.
  • DHS also said that the emergency staffing program is intended to help facilities staff during the surge we are currently experiencing. It is not intended to staff during non-surge times. The program will last, at a minimum, through the end of the year.

WHCA/WiCAL plans to submit additional questions and/or feedback to DHS regularly. Please contact Jim Stoa or Rick Abrams with any questions or feedback you have on the program.

Request Process to Obtain Temporary Agency Staffing Services

  1. Acute care, skilled nursing, long term care, and assisted living facilities will submit an initial interest request to DHS Health Staffing to receive the Agreement to Participate in Wisconsin DHS Surge Staffing Service and the Facility Eligibility for Services Questionnaire.
  2. Facilities will complete and return the Facility Eligibility for Services Questionnaire.
    1. Please be as specific as possible in documenting what the facility has done to mitigate staffing shortages to date.
    2. Note that the information collected on the Facility Eligibility for Service Questionnaire is for informational purposes only. Your answers will not disqualify you from participating in the Wisconsin DHS Agency Staffing Resource program.
  3. After receiving the completed Facility Eligibility for Service Questionnaire, DHS will request that the facility submit a Scope of Work detailing the services requested. DHS will then match the requesting facility with an appropriate temporary agency staffing vendor.

For additional information, to submit a request, or to submit a question related to staffing assistance requests please contact DHS Health Staffing.

For more information, please contact Pat Boyer at pat@whcawical.org or Rick Abrams at rick@whcawical.org.


Temporary and Emergency Nurse Aide Training

Temporary and Emergency Nurse Aide Training

On April 3, Governor Evers issued Emergency Order 21, which created the framework for two COVID-related nurse aide programs: the Emergency Nurse Aide program and the Temporary Nurse Aide program. Details on those programs are below. The order expired May 11, and DHS then published an emergency rule to extend those programs, but that Emergency Rule has now expired. As a result, DHS has reinstituted its individual facility waiver process.

For more information on securing a waiver, please contact WHCA/WiCAL Director of Government Relations and Regulatory Affairs, Jim Stoa, at jstoa@whcawical.org. Jim can walk you through the process and assist with submitting the request.

It is expected that DHS will allow these waivers to remain in place until the termination of the federal Public Health Emergency and applicable federal 1135 waivers.

Option 1: Emergency Nurse Aide Training

  • 16 hours initial training before direct care
  • Must be deemed competent to provide nursing services before direct care
  • 75 hours total (on-the-job training allowed)
  • Eligible for inclusion on nurse aide registry

Option 2: Temporary Nurse Aide Training

  • 16 hours initial training before direct care
  • Must be deemed competent to provide nursing services before direct care
  • Can provide services for which individual has been trained.
  • Not eligible for inclusion on nurse aide registry
  • Out-of-state CNAs can serve as Temporary Nurse Aides in Wisconsin

WHCA/WiCAL has confirmed with DHS officials that nurse aides certified in other states can serve as temporary nurse aides in Wisconsin. The temporary nurse aide program approved by DHS allows individuals to serve as nurse aides during the duration of the state’s public health emergency (please note: DHS officials have indicated there will be a grace period after the declared emergency ends, but the duration of that grace period has not yet been announced).

Infection Control Best Practices

Infection Control Best Practices

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DHS Rapid Assistance and Support Team (RAST)

DHS Rapid Assistance and Support Team

RAST offers a multidisciplinary approach to problem solving during a COVID-19 outbreak in nursing homes. DHS team members hear an overview from the facility or local/tribal health department, ask questions about the outbreak, provide technical assistance and make recommendations. Contact dhsrast@dhs.wisconsin.gov(link sends e-mail) for more information or to schedule a RAST call.

NOTE: If the assistance your facility seeks is solely related to a significant staffing shortage, please review the recommendations under the Planning for Staff Shortages heading below. If you have exhausted all of those recommendations, contact your Regional Director for further assistance.


Personal Protective Equipment

Personal Protective Equipment

In general, healthcare facilities should continue to follow the IPC recommendations for unvaccinated individuals (e.g., use of Transmission-Based Precautions for those that have had close contact to someone with SARS-CoV-2 infection) when caring for fully vaccinated individuals with moderate to severe immunocompromise due to a medical condition or receipt of immunosuppressive medications or treatments.

Other factors, such as end-stage renal disease, likely pose a lower degree of immunocompromise and there might not be a need to follow the recommendations for those with moderate to severe immunocompromise. However, fully vaccinated people in this category should consider continuing to practice physical distancing and use of source control while in a healthcare facility.

Ultimately, the degree of immunocompromise for the patient is determined by the treating provider, and preventive actions are tailored to each individual and situation.

PPE resources can be found below:


Infection Control Assessment Tool (ICAR)

Infection Control Assessment Tool (ICAR)

Infection Control Assessment and Response (ICAR) tools are used to systematically assess a healthcare facility’s infection prevention and control (IPC) practices and guide quality improvement activities (e.g., by addressing identified gaps).

Nursing homes and other long-term care facilities should prepare now to care for residents with COVID-19. A facility self-assessment tool is available to evaluate current readiness and guide development of a COVID-19 plan that addresses communications, supplies, resident management, visitors, occupational health, training, and surge capacity.

Facilities, especially those who have not had a case yet, can start by performing the self-assessment and direct questions about their results or the included components to dhswihaipreventionprogram@dhs.wisconsin.gov.

Long-term care facilities can also request a tele-ICAR evaluation by the HAI Prevention Program, which involves a more detailed phone-based infection control assessment of elements for COVID-19 readiness. The tele-ICAR is estimated to be about 30 to 60 minutes in length.

CDC also has a 30-minute webinar recording that walks through preparing nursing homes and assisted living facilities for COVID-19


Monitor Health

Monitor Health

Monitoring and surveillance are critical in this situation. Do what you can to stay healthy. If you feel sick, whether you’re an employee, a visitor, or a resident, speak up and stay home. But here’s what to do if someone in your community presents with a respiratory illness.

Remind yourself, staff, and residents to get plenty of rest; have regular, nutritious meals; and stay away from others who have cold and flu symptoms. By practicing self-care, you’re taking the best action against this virus.

Click HERE to view AHCA/NCAL’s COVID-19 Screening Checklist for Visitors and Employees

Click HERE to view a Start of Shift Daily Employee Screening Log

Encourage residents to report any illness they are experiencing, and staff should check residents for symptoms of fever, cough, shortness of breath every day.

Post notices that visitors who are sick in any way should refrain from visiting and work with staff on keeping in touch by phone or video calls.

Add signage at the front desk entrance reminding everyone to wash hands, use hand sanitizer, and practice respiratory hygiene.

Make sure staff gets the message to monitor and report any symptoms they or the  residents have. Review policies on sick leave and time off. You may want to check in at the beginning of work shifts to ask how staff are feeling, remind them to keep watching for symptoms among residents and visitors, and remind them of sick leave policies.

This applies to any temporary, on-call employment services and third-party health care providers as well–review policies with the agency and in person, when any other worker  arrives. Keeping an infectious disease out of the community is worth the time.

The Occupational Safety and Health Administration guidelines are the same as those found in this toolkit but having them on hand if there’s a workplace issue question could be useful.


Handwashing

Handwashing

Relearn how to wash your hands, review cough and sneeze etiquette, and get the facts about face masks.

Reinforce and remind yourself, residents, and staff about hand washing best practices. Watch or share this video, put this flyer on handwashing from ServSafe up in kitchen areas, and share the CDC’s instructions:

  • Wash with soap and water for at least 20 seconds.
  • Wash hands often, but especially after going to the bathroom; before eating; and after blowing your nose, coughing, or sneezing.
  • If soap and water are not readily available, use an alcohol-based hand sanitizer with 60 percent to 95 percent alcohol.
  • You may want to place hand sanitizer on dining room tables or in outside dining areas, for residents who can use hand sanitizer safely.

Cough, sneeze, and distance etiquette:

  • Cover coughs and sneezes with a tissue, then dispose of it in a trash can, preferably one with a touchless lid opener.
  • Avoid touching your eyes, nose, and mouth. This makes it more difficult for the virus to get from a surface to yourself.
  • Check your community for supplies of tissues, touchless trash cans, hand sanitizer, and soap.
  • Practice social distance: Keep about three feet between yourself and anyone coughing or sneezing.

Cleaning

Cleaning

Review best practices, clean the major touch points, and use the right cleaning products.

Coronavirus is an enveloped virus, which means it can be effectively killed with disinfectant, and it appears to be able to survive only a few hours on surfaces.

Check with your vendor to learn what cleaning products and supplies to use for disinfecting and how to use them properly. Use any cleaning products according to the manufacturer’s instructions, or they may not be fully effective.

The CDC recommends using “products with EPA-approved emerging viral pathogens claims.” This means that while it may be too soon to label a product as definitely killing this virus, products approved for emerging viral pathogens are recommended.

Residents in their own apartments or homes can use the same cleaners or wipes in their residences as they usually do.

The major touchpoints to clean are the same as those for the flu:

  • Doorknobs
  • Handrails
  • Elevator buttons
  • Phones
  • Keyboards
  • You may also want to put wipes out in communal areas such as game rooms or exercise studios.

Another tip: Add periodic wipedowns to the schedule or create a checklist of areas.

Use the appropriate cleaning solutions: The ones you use for regular flu-level cleaning are best, or see this EPA list of products.

WHCA/WiCAL Business Partner Resources

WHCA/WiCAL Business Partner Resources

Don’t forget to utilize our valued Business Partners for resources to help you during this time.

Click HERE to view WHCA/WiCAL’s Partners in Care.

Click HERE to view resources from WHCA/WiCAL Elite Premier business partner, M3 Insurance.

Click HERE to access a recording for a recent webinar entitled “Communications as a Risk Management Strategy” with M3’s Chris Kenyon, managing director of Senior Living & Social Services, Chris Halverson, risk management sales director, and Kimberly Kane, President and CEO of Kane Communications to discuss communication best practices and strategies for helping facilities manage communications in a crisis.


Infectious Disease Screening Solutions

Health-Key Infection Control Keyboard

CREST Healthcare Infection Control Solutions

Disinfect with Confidence: Plasma Air Purification Technology

AUVS Completes Your Hand Hygiene Program

CURAVI Health: A Partner for Long-Term, Post-Acute Care


Economic Relief Fund Expense Tracking Tool

Congress has provided trillions of dollars in economic relief to help businesses get through the financial challenges brought by COVID-19. These economic relief opportunities have specific rules for how they can be used, especially for health care organizations. Tracking and monitoring is critical, but can be very complicated, especially when funding is received from multiple sources.

CliftonLarsonAllen, WHCA/WiCAL Select Business Partner, has developed an expense tracking tool that creates the foundation to organize spending in accordance with compliance and reporting initiatives that are sure to follow.

Click here to see an overview of the tool and make a purchase.

Click here to access their Expense Tracking for Economic Relief Fund Recipients webinar that was hosted on May 15.

This webinar covered allowable uses, latest updates on terms and conditions of HHS, key tips and insights on effective tracking and a more detailed overview. The presentation slides are also available at this link.


Fusion’s here for you in a crisis!


Preferred Podiatry partnered with Polaris to offer an Infection Control Program Risk Assessment and Interim Staffing.


Pathway Health has designed a Leadership Preparation Strategies Guide for leadership providing strategies for addressing COVID-19.

Click HERE to view a full set of complimentary COVID-19 resources for your use, including policies and procedures, leadership checklists, and preparation and response strategies.


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Shared Purchasing Solutions

Shared Purchasing Solutions/Health Resource Services, an affiliate of Intalere, is closely monitoring the Coronavirus’ impact to the global healthcare supply chain, including the ongoing demand for personal protective equipment (PPE).

HRS/Intalere is providing updated information including supplier updates and resources as they become available through their Operational Continuity & Emergency Management team.

In addition,HRS/ Intalere advises practices to consider the following tips when making supply orders:

  • Prioritize ordering from your current suppliers – Every vendor is going to service their existing customers on the items they currently purchase before moving on to expanded product orders from current customers and orders from new customers.
  • Increase your order volume wisely – Practices may decide to increase the volume of their standard orders as a preventative measure, but it is important to keep in mind that suppliers are closely monitoring order volumes and may cancel large orders to prevent the hoarding of supplies. In most scenarios, a marginal increase (5 cases of a product as opposed to the standard order of 3 cases, for example) will not trigger order cancellation.
  • Place additional orders with a variety of vendors – By marginally increasing the volume of your orders with your current vendors and by placing additional small orders at a variety of suppliers, you can increase the likelihood of receiving your practice’s needed supplies in a timely fashion.
  • Reduce the “burn rate” (usage) of hand sanitizer and other Personal Protection Equipment (PPE) –   It’s estimated that over 60% of the PPE products used in the United States are manufactured in China, which means vendors are receiving these products at a much slower rate, if at all.

For more information, please contact Stacey Royston, Stacey.Royston@Intalere.com or at (608) 239-1372

Archive

Archive

On July 30, Governor Tony Evers declared a new public health emergency  and issued an Emergency Order requiring all Wisconsin residents to wear face masks while indoors until the end of September. That order has been renewed and remains in place.

The order, which took effect on August 1, requires masks for anyone age 5 or older while indoors except at a private residence. Violating the order could result in fines of up to $200.

PREVIOUS STATEWIDE STAY-AT-HOME ORDER HAS ENDED: On March 24, Wisconsin Governor Tony Evers issued a “Safer at Home” order , which was extended and was supposed to be effective through May 26. The Wisconsin Supreme Court struck down the extension of the Safer at Home order on Wednesday, May 13 on a 4-3 vote saying that it was “unlawful” and “unenforceable.”

Some local counties and municipalities have imposed local restrictions similar to the previous statewide stay-at-home order. For the most up-to-date information, please reach out to your local health department.

Wisconsin – Visitation is dictated by this CMS memo. Find out more information here.

This CMS memo had limited SNF survey activity, but it will be phased out in place of this CMS memo, which creates a very punitive survey/enforcement framework moving forward. WHCA/WiCAL has reached out to DQA and AHCA about these changes.

DHS has released visitation guidance for assisted living centers, available here.

DHS has also released visitation guidance for on-site hair salon and barber services, available here.

On June 10, DHS released three new guidance documents for long-term care facilities related to COVID-19:

1135 waivers are still in effect. Since assisted living facilities are not governed by CMS, the CDC and DHS do continue to recommend visitation restrictions.

While long term care facilities practice quality infection control procedures, the coronavirus (COVID-19) has heightened focus on infection prevention and control. We are providing resources to assist long term care facilities with issues surrounding the COVID-19 and this rapidly evolving situation.

The WHCA/WiCAL staff are readily accessible to the membership and their employees to assist during the public health emergency. Please do not hesitate to contact a staff member at the email or phone number listed below:

 

Rick Abrams, J.D.
CEO
Rick@whcawical.org | C: (516) 241-2879 | O: (608) 257-0125
Jim Stoa, J.D.
Director of Government Relations and Regulatory Affairs
Jstoa@whcawical.org | C: (608) 436-3952 | O: (608) 257-0125
Pat Boyer, MSM, RN, NHA
WHCA/WiCAL Director of Quality Advancement and Education
Pat@whcawical.org | C: (414) 690-7898 | O: (608) 257-0125
Kate Dickson, MPA
Director of Reimbursement Policy
Kate@whcawical.org | O: (608) 257-0125
Kate Battiato, MPA
Director of Workforce Development
Kbattiato@whcawical.org | C: (608) 260-5865 | O: (608) 257-0125
Jena Jackson
WHCA/WiCAL Director of Development
Jena@whcawical.org | C: (608) 279-5615 | O: (608) 257-0125