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Reopening Nursing Homes – Phase 1 – How Does It Begin?

On May 18, 2020, The Centers for Medicare & Medicaid Services (CMS) issued a QSO Memo, “Nursing Home Reopening Recommendations for State and Local Officials.” These recommendations include a list of factors and considerations for making decisions on when it is safe to reopen nursing homes as part of the larger US “Opening Up America Again” guidelines. The Opening Up America Again plan – in case you are not familiar with it – includes a three-phased approach with gating criteria that must be met to “open” a state or region back up. In the new QSO Memo, CMS has included an attachment, “Recommended Nursing Home Phased Reopening for States” which crosswalks the guidelines for the three phases of the White House guidelines.

Summary of the “Recommended Nursing Home Phased Reopening for States” Guidance for Phase 1

Since the residents of nursing homes have an elevated risk for COVID-19, additional criteria than what is provided in the White House framework has been recommended for nursing homes to be able to reopen. What has been highly publicized is that nursing homes as a whole should generally not “reopen” until Phase 3, but what do you need to know about how to get there?

When a community has met the criteria to begin Phase 1 of Opening Up America Again:

CMS recommends that nursing homes can begin their Phase 1 reopening when this occurs, but provided the following recommendations for facility practices:

  • It is recommended that nursing homes remain in their current state of high mitigation for 14 days after the community begins Phase 1. This is essentially where we are now, with visitation continuing to be generally prohibited except for compassionate care situations, restriction of non-essential healthcare personnel entering the facility, and restricting non-medically necessary trips outside the building for residents. If a resident does leave the building, the resident must wear a cloth face covering or facemask and the resident’s COVID-19 status needs to be provided to the transportation provider and the provider that the resident is going to for the appointment.
  • Communal dining is limited – for COVID-19 negative and asymptomatic residents only –residents are allowed to eat in the same room so long as social distancing is in place through limiting the number of residents at the same table and using 6 foot spacing. Some group activities may be conducted, although limited – for COVID-19 negative and asymptomatic residents only. Social distancing, use of cloth face coverings or facemasks and hand hygiene must be performed.
  • All persons entering the facility must be screened and all staff must be screened at the beginning of their shifts. There must also be 100% screening of residents through temperature checks, and at least once daily, questions about and observation for signs or symptoms of COVID-19.
  • Regarding PPE, all staff must wear appropriate PPE when they are interacting with residents (to the extent PPE is available and in accordance with CDC guidance on optimizing PPE). Staff wear a cloth face mask if a facemask is not indicated. Universal source control is in place for everyone in the facility and residents and visitors entering the facility for compassionate care must wear a cloth face covering or face mask.
  • Here’s where some facilities and states may run in to trouble until things are squared away with access to testing, which has accelerated across the country since the Trump Administration recommended everyone in nursing homes be tested: All staff are tested weekly. Upon identification of an individual with symptoms consistent with COVID-19 or if staff have tested positive for COVID-19, all residents are tested.
  • The facility should have dedicated space for cohorting and managing COVID-19 care for positive residents.
  • Facilities also need to have a plan for managing new admissions/readmissions with an unknown COVID-19 status and for residents who develop symptoms.

What to Expect on Survey during this Phase:

  • Complaint investigations of potential Immediate Jeopardy-level situations
  • Revisit surveys to confirm a facility has removed an IJ findings
  • Focused Infection Control Surveys
  • Initial certification surveys

We will be providing more information on this topic in future CMSCG Blog posts. To read the CMS QSO Memo, “Nursing Home Reopening Recommendations for State and Local Officials,” (Ref: QSO-20-30-NH), click here. View our CMSCG Blog post,”CMS Issues Nursing Home Reopening Recommendations” for a recap of what’s in the memo.

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