The Centers for Disease Control and Prevention (CDC) recently released updates to infection control guidance. In turn, the Centers for Medicare and Medicaid Services (CMS) updated its own guidance for nursing homes in those subject areas to align with CDC’s new recommendations.

WHCA/WiCAL has shared a detailed summary of the changes, available here. We also have heard from providers seeking additional clarification. Immediately below are new questions which WHCA posed to DQA, with DQA’s response in red.

• • Considering the new guidance documents’ discretion to providers to implement an infection control plan that best meets facility/resident/staff needs while also adhering to guidance parameters and appropriately incorporating community transmission levels, will DQA advise surveyors to solely base their conclusions on whether the facility’s plan/policies fall within the scope of the new guidance (given external factors like community transmission levels etc), and that the plan/policies are carried out as is detailed in the facility’s infection control policy?
    • Yes. In addition to the updated guidance, providers should have a process in place that describes how providers will make changes to interventions based on changes in community transmission levels. https://www.cdc.gov/coronavirus/2019-ncov/hcp/faq.html#Infection-Control:~:text=Top%20of%20Page-,Infection%20Control,-When%20should%20healthcare
• • Can you please explain how a facility should proceed with a new admission to a double-occupancy room? Would the new admission be required to wear a mask in the room for 10 days? What about the roommate?
    • Ideally, you would place the new admission in a single-person room and have them wear source control for the first 10 days after admission.
    • If a single-person room is not available, the facility may choose to cohort as an alternative approach and source control should be worn by both residents.
    • If, however, the new admission or the current resident test positive for SARS-CoV-2, it would be recommended for the positive resident to move to another room, preferably a single-person room or to a specified unit for residents positive for SARS-CoV-2 infection.

• • Eye protection – if a facility is not in an outbreak, is eye protection a consideration, as opposed to a requirement?
    • Yes, eye protection is a consideration. During high community transmission, the facility should consider having HCP use eye protection during patient care encounters.

• • With the new CDC/CMS guidance, is there no longer a requirement for daily screening for COVID symptoms of every resident in the building? Can facilities stop the daily/non-outbreak resident COVID screening? The feedback we have heard from providers is that this is incredibly time-intensive.
    • According to communication with the CDC, there is currently no specific recommendation for daily monitoring to include temperature monitoring, however each nursing home should ideally have a COVID-19 plan in place to assess & monitor for signs and symptoms related to SARS-CoV-2 . 
    • F880 states The facility must establish an infection prevention and control program (IPCP) that must include, at a minimum, the following elements:
      • §483.80(a)(1) A system for preventing, identifying, reporting, investigating, and controlling infections and communicable diseases for all residents, staff, volunteers, visitors, and other individuals providing services under a contractual arrangement based upon the facility assessment conducted according to §483.70(e) and following accepted national standards;
      • §483.80(a)(2) Written standards, policies, and procedures for the program, which must include, but are not limited to:
        • (i) A system of surveillance designed to identify possible communicable diseases or infections before they can spread to other persons in the facility;
    • The facility’s surveillance policies should identify how surveillance for communicable diseases is conducted to prevent, identify and control communicable diseases to include but not limited to SARS-Co-V-2 and influenza among their residents, staff, volunteers, visitors, and other individuals providing services under a contractual arrangement.

Do you have other questions you would like WHCA/WiCAL to ask regulators, such as DQA or CMS, related to the new CDC/CMS updates? Please contact Jim Stoa or Jena Jackson.