In Focus Newsletter October 29, 2020
October 29, 2020
2020 Spotlight on Excellence
Indoor Visitation for Voting Purposes: Last week CPDHE released guidance related to voting assistance for long term care residents. The statement read:
“Visitation by a family member, friend, or employee of the county clerk and recorder or representative appointed by a major political party pursuant to C.R.S. § 1-7.5-113, to help a resident vote shall be permitted under the same conditions as a compassionate care visit until polls close on November 3, 2020. Visitors assisting residents to vote shall maximize prevention by being screened for symptoms, wearing a mask at all times, visiting outdoors if possible, and other prevention measures that may be required by the facility. COVID-19 testing is not required for this visit under this limited circumstance. A similar visit in the limited circumstance that a ballot may need to be cured is also permitted through November 12.”
State Indoor Visitation Policy: While the state and federal government have both issued guidance for indoor visitation, CDPHE has made it clear that providers in Colorado will be held to the State guidance, and CDPHE will not be surveying to the federal guidance at this time. If you are considering indoor visitation, please review Colorado’s Indoor Visitation Guidance. Please contact Ann Kokish (AKokish at COCHA.org) with specific questions.
Working with the State on Admission Holds, Visitation, and Antigen Testing: CHCA has been working with the Governor’s Residential Care Strike Force to request changes in all three policies that the state has implemented. While we do no have firm timelines for expectations around change in these areas, a brief update on the conversations taking place can be found below:
14 Day Admission Hold: We realize that the 14-day admission hold for any positive cases has had a deeply negative impact on census throughout the pandemic. In many instances the 14-day admission hold has been extended by local health departments, and the policy has been inconsistently administered at the county level. Specifically, the state indicates that bans should be put in place for new RESIDENT cases, but some counties have extended the ban to situations where new EMPLOYEE cases arise. The Strike Force has shown a willingness to create an admission ban policy that would allow a provider to clear the band when certain thresholds have been met (ie. new round of baseline testing, ability to quarantine, and appropriate levels of staffing and PPE). At the same time we are requesting a revision to the Public Health Order that would put all Ban decisions in the hands of state regulators, unless a county applies for an exception. The state is working through these considerations.
Antigen Tests: With the distribution of three types of antigen tests to long term care providers, the federal government has been clear that they expect these tests to be a meaningful part of the solution to this pandemic. However, at this point state policy has restricted the use of antigen tests to counties that have the highest levels of community transmission. Unfortunately, the last few weeks have seen rapid increases in community-level spread of Covid. This has led to capacity struggles and timing issues with laboratory results. CHCA has been working with the Governor’s Residential Care Strike Force to create a policy that would allow for more widespread use of antigen tests.
Indoor Visitation Changes: The current structure of the state’s indoor visitation policy is so restrictive that the state reports that less than 2% of facilities are actively allowing indoor visitation. Additionally, HCPF is offering CMP grants for the purchase of outdoor visitation tents, but current life safety guidance disallows the use of heaters in those tents. As the holidays approach there is meaningful concern that if visitation guidelines aren’t relaxed many families will opt to take their loved ones outside of the care community for holiday celebrations. This practice could lead to virus spread in LTC. CHCA is working with the state to create some type of holiday visitation guidance in addition to re-working the overarching indoor visitation policy to allow it to be more widely used.
CDPHE Checklist: CDPHE has developed a Preparation and Rapid Response Checklist for residential care facilities. All providers should consult the checklist to ensure proper preparation for potential outbreaks and ongoing operational readiness related to Covid. The checklist will be updated by CDPHE periodically.
Keeping Up to Date
Value Based Purchasing: The federal government has announced the release of the first round of incentive payments to nursing home providers. These payments are meant to serve as an incentive for nursing homes to keep their Covid infection rates and morbidity rates lower than the communities they serve as compared to CDC data. Yesterday CMS announced that $333 Billion in payments for the September reporting period would be sent out to providers the week of November 2nd. While CHCA does not know the exact methodology that was used to calculate payments, CMS’s press release shows that 178 facilities in Colorado qualified and that $2.4 Million will be distributed to those providers.
Vaccine Signup: The deadline for long term care facilities to sign up to participate in the Pharmacy Partnership for Long-Term Care Program has been extended to Friday, November 6. Please don’t wait to register for the federal government’s national vaccine distribution program for long term care residents. Long term care facilities must register with the CDC on how they want to receive and administer the COVID-19 vaccine when it becomes available. Nursing homes register via NHSN, while assisted living communities and other congregate settings sign up through an online survey.
Ideas for Celebrating the Holidays: As the holidays approach us, we know that everyone is searching for ways to help our residents celebrate in these challenging times. Thanks to our friends at Vivage Senior Living for sharing some great ideas for Celebrating the Holidays During Covid.
30 Day Notices: While our current discharge requirements have been in existence for quite some time, the state did create a 30-day discharge form about two years ago for provider to be able to use as a template. There have been a few recent interactions between providers and ombudsmen that imply the use of this specific form is required. CHCA’s General Counsel advises that the form is not required, and that other more customized notifications should be considered. For an brief overview of the requirements, and recommendations on how to craft a more customized notice, please see an Overview from Attorney Fred Miles of Greenberg Traurig.
Health & Wellbeing Questionnaire: We all know the challenges that the pandemic has posed for attending to the health and wellbeing of our residents. The state of Colorado is looking for best practices that have been employed throughout the pandemic to be able to share with other providers. If you have been doing something unique to help meet the needs of your residents, the state would appreciate your assistance in completing a short Questionnaire.
AHCA/NCAL Quality Awards Program: The AHCA/NCAL National Quality Award Program provides a pathway for providers of long term and post-acute care services to journey towards performance excellence. The program is based on the core values and criteria of the Baldridge Performance Excellence Program.
Member centers may apply for three progressive levels of awards: Bronze—Commitment to Quality, Silver—Achievement in Quality, or Gold—Excellence in Quality. Each level has its own distinct rigors and requirements for quality and performance excellence. Applications are judged by trained Examiners who provide feedback on opportunities for improvement to support continuous learning. To begin the Quality Award Process, centers must submit an intent to apply by November 12, 2020. For more information, please visit the AHCA/NCAL National Quality Award Program Website
Project ECHO: The federal government is partnering with Project ECHO (Extension for Community Healthcare Outcomes) to launch a national Nursing Home Covid Action Network. The purpose of the project is to advance improvements in Covid 19 preparedness, safety, and infection control. This project launched very quickly and is in the final stages of development. Project ECHO is currently recruiting “Hubs” in each state so serve as technical assistance and guidance. We expect to know which organizations will be serving as Colorado hubs in the coming week. Participation is free, and participating facilities will qualify for reimbursement to help cover the costs of participating facility staff. Please review the ECHO Action Network FAQs for information, and a link to register your intent to participate.
Legal Survey: CHCA is aware that a number of legal actions have been filed against long term care providers across the country in relation to Covid 19. In an effort to inform public policy and defend the profession in relation to these lawsuits, CHCA is asking that members share information about any cases that might be filed in Colorado. Specifically, we are interested in knowing about cases that allege a failure to follow public health orders, CDC or CMS guidance related to Covid matters. If you have questions about this request or information to share, please contact Doug Farmer (Dfarmer@cohca.org)