The Centers for Disease Control and Prevention (CDC) recently released updates to infection control guidance. WHCA/WiCAL has shared a detailed summary of the changes, available here.

For nursing home providers, CMS released revised survey/enforcement guidance meant to align with the new CDC guidance. However, AL providers have been looking for additional clarification from the state on how the new guidance impacted AL facilities’ abilities to adjust or relax staff masking policy. Below is a summary that WiCAL has confirmed with the DQA Bureau of Assisted Living (BAL) on what surveyors will be considering for AL facilities’ masking policies in light of the new CDC guidance.

***Please note: WHCA/WiCAL advises members to discuss any plans to change their staff source control policy with their regional Infection Preventionist to ensure your policies/procedures align with CDC guidance. Find your local Infection Preventionist HERE (scroll about halfway down the page).***

ASSISTED LIVING SOURCE CONTROL CONSIDERATIONS BASED ON AL SETTING

In general:

• CBRF are statutorily defined as health care facilities, and thus must follow new CDC guidance for source control based on community transmission levels.
• RCAC and AFH can potentially use the community level metric, rather than community transmission level.

Functionally, this would mean that for survey/enforcement purposes on source control, CBRF are required/expected to follow this CDC guidance:

When SARS-CoV-2 Community Transmission levels are high, source control is recommended for everyone in a healthcare setting when they are in areas of the healthcare facility where they could encounter patients.

• • HCP could choose not to wear source control when they are in well-defined areas that are restricted from patient access (e.g., staff meeting rooms) if they do not otherwise meet the criteria described below and Community Levels are not also high. When Community Levels are high, source control is recommended for everyone.

When SARS-CoV-2 Community Transmission levels are not high, healthcare facilities could choose not to require universal source control. [additional considerations listed in guidance]  

For RCAC and AFH, outside of outbreak, surveyors will review to make sure that an RCAC or AFH has a plan in place and is following it, based on the metric they choose as their “trigger” (i.e., community levels or community transmission levels). So, these settings have more flexibility to relax source control requirements as long as it is laid out in their infection control policy and is metric-based.