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Reopening Nursing Homes – Phase 2 – What’s Recommended?

On May 18, 2020, The Centers for Medicare & Medicaid Services (CMS) issued a QSO Memo that provided recommendations on reopening nursing homes. Phase 2 of Reopening Nursing Homes and Opening Up America Again requires multiple criteria to be met before implementation. These include:

  • Case status in the community has met the criteria for starting Phase 2. Specifically, this requires that there is no rebound in COVID-19 cases in the community after 14 days in Phase 1.
  • The nursing home:
    • Has had no new, nursing home-onset COVID-19 cases for 14 days.
    • Is not experiencing staff shortages.
    • Has adequate supplies of Personal Protective Equipment (PPE) and disinfection supplies to care for residents
    • Has adequate access to COVID-19 testing
  • Referral hospitals have bed capacity on units as well as intensive care units (ICU).

What CMS Recommends in Phase 2

Much of what is recommended in Phase 1 continues to be recommended for Phase 2, including:

  • Visitation – General restriction of visitation, except for compassionate care situations.
  • 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.
  • Screening – 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.
  • Testing – 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.
  • Dedicated space in facility – Facilities need to have a plan for managing new admissions/readmissions with an unknown COVID-19 status and for residents who develop symptoms.

The recommendations that are different from Phase 1 include:

  • Limited numbers of non-essential personnel/contactors may be allowed in the facility, as deemed necessary by the facility. These individuals must take precautions – wear a cloth face covering or facemask, perform hand hygiene and maintain social distancing and they all must be screened.
  • Group Activities – These activities, as well as outings, may be planned for COVID-19 negative or asymptomatic residents only, but may not include more than ten people and residents must socially distance, perform appropriate hand hygiene and wear a cloth face covering or facemask.
  • PPE – In this phase, it is expected that all staff wear appropriate PPE – in Phase 1, the recommendation comes in accordance with CDC guidance on PPE optimization – but by the time Phase 2 is being implemented, the facility is expected to have adequate PPE for staff to use when indicated. All staff should wear a cloth face covering if use of a facemask is not indicated, such as for administrative personnel.

What to Expect on Survey during this Phase:

  • Complaint investigations of potential Immediate Jeopardy-level situations or actual harm to residents. In Phase 1, these investigations were limited to IJ-level complaints only.
    • The Appendix of this document directs states to prioritize investigations of Complaints and Facility-Reported Incidents and facilities with reports/allegations of the following:
      • Abuse or neglect
      • Infection Control  – including failure to meet COVID-19 reporting requirements to residents/representatives
      • Transfer or discharge violations
      • Insufficient staffing
      • Staff competency issues
      • Other quality of care issues  – falls, pressure ulcers and other high-risk concerns
  • Revisit surveys to confirm the facility has removed IJ findings
  • Focused Infection Control Surveys
  • Initial Certification Surveys
  • State-based priorities – surveys in “hot spots” and other priorities. CMS notes that State Agencies may consider other factors in prioritization, such as a trend in allegations of risk of harm to residents.

Check back on the CMSCG Blog as we review what it means to reopen nursing homes in America and what providers should expect on survey as we move towards a post-pandemic “normal.,” including Phase 3 of the reopening guidelines. For more information:


To learn about CMS Compliance Group’s COVID-19 Consulting Services, please visit this page. To contact us about our services, please call 631.692.4422 or email us at info@cmscg.net.

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