The Centers for Medicare & Medicaid Services (CMS) issued a QSO Memo on May 18, 2020, “Nursing Home Reopening Recommendations for State and Local Officials.” Much like the title of the Memo implies, CMS has provided recommendations in this document to assist state and local officials with determining the level of mitigation required to prevent further transmission of COVID-19 in nursing homes. These recommendations include examples of how state officials may choose to go through each of the reopening phases, including an option to make all nursing homes in a state go through the phases at the same time, or to allow individual facilities to enter through the phases as they meet the criteria, or to allow regions to enter phases at the same time.
CMS provided a list of factors for officials to consider when they are planning for reopening nursing homes, and many of them take into consideration the surrounding community, so even if by some chance your facility has managed to keep COVID-free, if the surrounding area has not, your reopening may be delayed. The factors include:
- Community Case Status – States should have criteria in place to determine levels of community transmission and use those for guiding their states through the Opening Up America Again guidelines provided by the White House.
- Nursing Home Case Status – CMS recommends that nursing homes do not have any nursing home-onset of COVID-19 cases for either residents or staff in the facility. This will likely be based on the reporting that facilities are doing to their state health and local health departments, so it’s important to ensure this information is current.
- Nursing Home Staffing Adequacy – Facilities that do not have adequate staffing levels or require a form of contingency staffing may not be ready for reopening.
- Testing Access – Facilities should have a testing plan in place that is based on contingencies informed by CDC guidance3. CMS notes that a facility testing plan should include multiple components, including the capacity for all nursing home residents, staff (including volunteers and vendors) to receive a single baseline COVID-19 test. Included in the plan should also be the capacity to test all residents if there is an individual who exhibits symptoms consistent with COVID-19, or if a staff member tests positive. CMS recommends that re-testing be completed every week, but state/local officials can make adjustments for weekly testing based on transmission data.
- Facilities should have written screening protocols in place for all staff each shift, all residents daily, and anyone entering the facility (including visitors, volunteers and vendors)
- Facilities should also have an arrangement with laboratories to process tests. Testing should be able to detect the SARS-CoV-2 virus with greater than 95% sensitivity, greater than 90% specificity and provide rapid results. CMS states that antibody test results should not be used for diagnosing someone with an active SARS-CoV-2 infection.
- Universal Source Control – All residents and visitors wear a cloth face covering or facemask. Visitors who are unwilling/unable to maintain these precautions should be considered for visitor restriction. All visitors must perform hand washing or hand sanitization upon entering the facility and must practice social distancing.
- Personal Protective Equipment for Staff – Facilities should have access to adequate PPE for staff, although contingency capacity strategy is acceptable, if facilities are in a crisis capacity PPE strategy, this would be prohibited. This means that all staff wear appropriate PPE when it is indicated and wear a cloth face covering if a facemask is not indicated, such as with administrative staff.
- Local Hospital Capacity – CMS recommends that local hospitals have the capacity to access nursing home transfers before nursing homes can reopen.
We will be looking at what is recommended for each phase over a handful of CMSCG Blog posts. Stay tuned for more, but to read the full QSO Memo (Ref: QSO-20-30-NH), please click here.
