CMS updates emergency preparedness requirements
Centers for Medicare & Medicaid Services (CMS) issued an updated QSO that provides clarification on the requirement to participate in a full-scale emergency preparedness exercise during the COVID pandemic.
SNFs and ICF-DDs that have activated their emergency plans during the current response can use that activation in lieu of the annual full-scale requirement. This will allow the response to be used for both 2020 and 2021, provided you activated your emergency plan in each year.
The requirement to participate in another exercise of your choice still applies, so table-top exercises or disaster drills can be used to meet this requirement.
For questions about the documentation of your exercises or how you can do your own exercises, please contact CAHF Director of Emergency Preparedness Jason Belden.
Cal OSHA revises emergency temporary standards
Special notice to employers under the ATD standard
Cal/OSHA has updated its emergency temporary standards (ETS) in response to the Newsom Administration's lifting of public health restrictions on businesses due to the COVID-19 pandemic.
While employers subject to the Aerosol Transmissable Disease (ATD) standard do not need to follow this guidance, it is important to understand that not all of your employees may be covered under your plan.
If you plan to cover all of your employees under the ATD standard, that specifically needs to be written into your plan. Cal/OSHA field representatives are actively seeking this information when they do site visits and investigations.
For those of you with corporate offices or other types of services on your site, the emergency temporary standards would apply to those employees that are not covered under your aerosol transmissible disease standard plan.
The best resource to explain the revisions can be found here.
COVID vaccination data reporting to NHSN
Questions loom about CDPH's reporting for facilities
As you know, Centers for Medicare & Medicaid Services (CMS) gave providers until June 20 to begin reporting their COVID-19 vaccination data of residents and staff.
However, questions still loom over whether California Department of Public Health (CDPH) can accurately pass along the data for facilities so that they aren't subject to civil monetary penalties (CMP) for incorrect reporting.
CAHF has been in frequent communication with CDPH regarding the preliminary numbers shown on the COVID-19 Nursing Home Data website, as the data shown is not up to date and shows minimal participation in the reporting requirement.
According to the CDPH data team, they submitted data for 1139 facilities. That data showed good initial results with both residents and staff averaging over 80 percent. We do not have the data to verify that yet and will have to wait to make sure NHSN is receiving the correct data and it reflects what CDPH submitted.
In the interim, CAHF recommends that every facility verify its data on the NHSN website to ensure that the data entered is correct. If it is incorrect, each facility can adjust their own data independently. You will need to enroll in NHSN, if you have not already.
CAHF is soliciting input from providers if they have noticed either data entry errors and/or any notification of a CMP issued by CMS. If you or your facility is having issues please reach out to one of CAHF's staff contacts listed below.
Staff contacts: Patti Owens, 916-432-5201 and Jason Belden, 916-432-5194
Clarification on visitation guidance for SNFs and ICF-DDs
As you may know, on June 16, California Department of Public Health (CDPH) released guidance pertaining to visitation guidance.
AFL 20-38 was originally addressed to “All Facilities,” while also noting that “LTC providers refer to AFL 20-22.8” for guidance.
Because the AFL's language confused many providers, CAHF contacted CDPH for clarification and the department responded, stating that the guidance does not apply to SNFs and DDs.
CDPH updated the language to the following:
For additional visitation guidance applicable to SNFs, please see AFL 20-22.8 and for guidance applicable to the various kinds of ICF/DD facilities please see AFL 21-14.
See the updated AFL here.
