KAHCF/KCAL stands by your side during this particularly challenging time. We know that having the most up-to-date, accurate information is vital to keeping your residents and staff safe. At this time, we are participating in daily “huddle” calls with the OIG, DAIL, Omudsman, and KSLA and LeadingAge so that everyone is receiving the same information. Therefore, please follow these guidelines to assist in streamlining the communication process for everyone:
Please send all COVID-19 related questions to email@example.com so that we can appropriately channel and respond. Also, DAIL and the OIG report that they are inundated with questions - many that are duplicates. It would be helpful to everyone if questions are funneled through the association in order to assist them and all members.
The Kentucky COVID-19 Hotline for questions is 1-800-722-5725.
It is recommended that you designate one staff person to be responsible for checking the following on a daily basis for updates:
Centers for Disease Control’s COVID-19 Information
Kentucky Department for Public Health
General COVID-19 Information
Guidance for Long Term Care Facilities
If you have a suspected case of COVID, have your provider call one of the following numbers: (502) 564-5459 or 1-888-404-1539.
It is strongly recommended that all levels of care follow the CDC and CMS guidelines regarding visitation, activities and screening given that the population we serve is the most vulnerable to this virus.
Please understand that these measures - while drastic - are an attempt to prevent the introduction of the virus INTO your facility and to reduce the impact on acute care that may swell should the virus continue to spread.
Tune in to Governor Beshear’s daily briefings on his Facebook page for updates.
- NEW! CMS released new guidance & tools related to the prioritization of surveys (concentrating on infection prevention and COVID-19). Please take a look and use the self-assessment tool to prepare.
- The targeted infection control survey (included in the above link) is a new tool that builds upon existing guidance
- The communities where cases have already been identified are where the targeted infection control surveys will first be focused in order to attempt to stop the spread of the virus, so these areas should be prepared.
- The targeted infection control surveys will ALSO be used on all complaint surveys and will be used by both state and federal surveyors.
- It is recommended that you be fluid and update your facility policies as you learn and the guidance changes.
- NEW! CMS released Frequently Asked Questions on Medicare Provider Enrollment Relief related to COVID-19 including the toll-free hotlines available to provide expedited enrollment and answer questions related to COVID-19 enrollment requirements. A copy of the FAQs can be found here
- NEW! CMS makes ‘unprecedented’ quality reporting changes, releases Section GG tutorials. CMS announced it is granting exceptions from reporting requirements and extensions for clinicians and providers participating in Medicare quality reporting programs with respect to upcoming measure reporting and data submission for those programs.
- CMS Announces Relief for Clinicians, Providers, Hospitals and Facilities Participating in Quality Reporting Programs in Response to COVID-19
- CMS makes ‘unprecedented’ quality reporting changes, releases Section GG tutorials
- NEW! CMS is delaying the Minimum Data Set (MDS) 3.0 v1.18.1 release, which had been scheduled for October 1, 2020, in response to stakeholder concerns. The MDS item sets are used by Nursing Home and Swing Bed providers to collect and submit patient data to CMS. This MDS data informs payment, quality, and the survey process. Please direct any comments or questions regarding the above information to MDSCodinganswers@cms.hhs.gov.
- CMS Long Term Care Nursing Homes Telehealth and Telemedicine ToolKit
Interim Guidance on Extensions for AHA Instructor & Provider Cards during COVID-19 Outbreak from American Heart Association
C2 Strategic Communications & KAHCF/KCAL are offering a free webinar to members on Wednesday, April 1, 2020 at 10:30 a.m. EST. "Communicating in a Crisis: Lessons for COVID-19" will give decision-makers and communicators timely advice to better navigate the uncharted waters of COVID-19 and build confidence among staff, residents, and families. The presentation will include a Q&A session.
Preventing the Spread of COVID-19 in Retirement Communities and Independent Living Facilities (Interim Guidance)
Info on state testing labs is in the FAQ section below under "Testing"
New COVID-19 Screening Checklist for Visitors and Employees
For Jefferson County facilities - The official process to request PPE is in the FAQ's below under "PPE" or click here to download the printable instructions and forms.
KAHCF Board of Directors meeting postponed to Tuesday, May 5.
The Day in Keeneland on April 22, 2020 has officially been cancelled.
NIPP 2.0 Training scheduled for April 14-15th has been cancelled and will be rescheduled at another date. Check the KAHCF website.
Activity Director Training scheduled for April 20-24 has been postponed to June 22-26, 2020. At this time, we will re-register everyone who is registered for this course. If you have any questions, please contact Angela Porter.
KAHCF 2020 Quality Summit has been rescheduled for June 8-9, 2020. Please make sure to contact the Embassy Suites to change your reservation, they will not automatically do that for you. If you however have registered for the May dates, we will re-register everyone who is registered for this conference. If you are unable to attend, please contact Angela Porter.
- Team Kentucky Fund - Governor Beshear has established a relief fund to provide financial assistance to those who have lost their jobs or need additional assistance due to COVID-19. To donate to the Team Kentucky Fund, please click here.
- Louisville Metro Government has created a webpage to help lift our spirits during the fight against COVID-19. Lift Up Lou helps you stay connected, provides ideas and stories, and is a great resource to find services and report issues.
- Buffalo Trace Distillery is donating Clear Spring 190 proof spirit hand sanitizer during the COVID-19 health crisis. They are offering 1 case (12 bottles) per applicable Kentucky based organization: first responders, health care, government, law enforcement, 501(c)(3) organizations, etc. To be considered and pick-up information, please fill out this form.
- The Kentucky Distillers Association and the Kentucky Chamber created the website kyhandsanitizer.com to determine the critical need for hand sanitizer across employers in Kentucky. Please fill out this form if you need and would like to be considered for these supplies from our Kentucky bourbon distillers. This form helps create an efficient way to handle their overwhelming number of requests.
- Show this inspirational video "You Absolutely Matter" by Clint Maun to your fellow health care workers.
- If your facility has purchased or had donated cell phones, Ipads, and other technologies to keep residents in touch with family and friends, contact the Kentucky State Ombudsman, Sherry Culp at firstname.lastname@example.org. This will help them respond to concerns about access to communications.
- Bonnie from Foundation for a Healthy Kentucky and fellow church members are working hard to sew face masks for health care workers in Kentucky. To be considered for these face masks, please contact Bonnie at email@example.com or 502-552-3770.
- Tommy Cunningham from Murray, KY at Stroud Safety is transitioning seamstresses to producing face masks. The masks are $15.50 each and constructed from flame-resistant cotton with a pocket for adding a carbon insert. They have elastic bands to secure to head and a steel wire nose bridge. If interested in purchasing, please contact firstname.lastname@example.org or you can contact Stroud Safety in Oklahoma City at 405-632-2022.
Any reference to a specific product, process, or service does not constitute or imply an endorsement by KAHCF/KCAL of the product, process, or services, or its producer or provider.
FAQ's By Topic
Our OIG has communicated that it is absolutely imperative during this time that facilities continue to accept admissions from the community and transfers in order to keep acute beds open for those who need absolutely need them. We recommend that you screen admissions as you would staff and anyone entering the facility. The OIG has communicated with the hospitals that they need to be transparent about COVID-19 patients post-treatment needing placement in lower levels of care. It is a careful balance. Screen carefully and monitor temperatures and residents often. But accepting admissions is vital to keeping our healthcare system stable as a whole.
AHCA/NCAL Interim Guidance on SNFs Accepting Patients From Hospitals
AHCA is issuing interim guidance to help skilled nursing facilities (SNFs) make decisions about accepting hospital discharges to SNFs during COVID-19 pandemic. The decision-making and guidance will likely change as the prevalence of COVID-19 varies in communities and hospital surge increases in the community.
This guidance is designed to help reduce the risk of admitting someone with COVID-19 into your building, along with the steps you should take to prevent any spread. Please click here to read the PDF.
ALTERNATIVE CARE SITES
You were recently asked to fill out a survey regarding your plan for an alternative care site. As we explained in our recent alert, the Commonwealth is attempting to collect information in order to plan ahead for the expected hospital surge, as other states are also doing.
Learn more from the CDC about the purpose of alternative care sites here.
See what other states are doing to plan using alternative care sites by clicking the following links:
ASSISTED LIVING COMMUNITIES
The Department for Aging and Independent Living ("DAIL") issued new guidance for assisted living communities to help prevent the spread of COVID-19. Guidance provided by the CDC for assisted living communities that do not provide medical services can be found here. However, we still recommended that these facilities incorporate the more stringent requirements of the CMS guidance to the extent possible in an effort to protect their residents.
While - as of yet - individual care planning around isolation is not mandated by CMS, it is recommended by the OIG that facilities take a look at this recent McKnight’s article regarding the psychosocial effects of isolation.
We strongly recommend that you keep amended care planning documents with regard to this new situation and each resident - to whatever capacity your facility is able. We know that you and your staff are coming up with creative and interesting ways to keep your residents safe and emotionally stimulated.
Right now, it is understood that residents need to be in contact with their family members. Therefore, there is no privacy concern on behalf of the OIG or Ombudsman regarding staff using personal cell phones to allow residents to contact family members. This is appreciated and understood. For effective communication in the future, facilities will need to look at additional methods, but it is understood that this situation is unprecedented and was unforeseeable. It was suggested that staff use selfie sticks if available to save on wear and tear on their arms and backs and to afford residents a bit more privacy, but this is simply that - a suggestion.
CHILD CARE PROGRAMS
-From Kentucky Cabinet for Health and Family Services website
- Per the OIG, $50 per day is the YMCA recommended rate. Health care entities can work with child care entities to negotiate lower rates.
- ONLY for counties with no formal day care centers, only private sitters, the OIG will not regulate private sitters. Employees can use these private sitters and negotiate prices.
Attached is a PDF from AHCA/NCAL, which includes communal dining guidance for your facility.
Dining services for higher risk patients such as restorative dining for those who need closer supervision can be provided in a dining room but spread out as per the social distancing guidelines, however dining hours will need to be expanded in order to accommodate for social distancing and disinfecting between each set of diners.
The OIG is still working on a Kentucky plan and accompanying guidance regarding transfers, taking admissions of COVID-19+ residents post-hospital stay, etc. We hope to receive information next week. In the meantime, please refer to this AHCA RESOURCE re: discharge & transfer.
If you haven’t already, be aware that your facility will soon be asked to electronically fill out a ReadyOp form that will report to Frankfort how many open beds exist in your facility daily. It is recommended that you assign a staff member someone to fill out and send in every day.
The OIG has a standing call with the Kentucky Hospital Association and KAHCF/KCAL requested that he express the importance of transparency and honesty regarding diagnoses when hospitals are discharging patients to lower levels of care.
The OIG has stressed the importance of keeping acute beds free for those who need them and accepting transfers and discharges as usual with the proper COVID-19 screening as you would anyone entering your facility. Then, it is recommended that you frequently monitor these residents for signs/symptoms following admittance, as you are all residents.
Our industry should show great restraint in discharging residents for non-payment at this time. It is also believed that Medicaid applications may be delayed due to family members not being able to gather paperwork due to restricted access. If you have a resident who is facing involuntary discharge for non-payment, please contact Sherry Culp at email@example.com or 859.277.9215.
EMERGENCY PREPAREDNESS PLAN
In your emergency preparedness plan, it is recommended by the OIG that you identify those residents that will be hard to isolate (wanderers, roamers) and plan for isolation. These individuals are likely to be first to contract illness due to their roaming habits and will also be difficult to isolate - so planning ahead is essential.
You and your staff are likely adjusting to this situation as needed, because it’s impossible to anticipate every twist to a scenario. Don’t forget to note what actions you are taking and update your emergency preparedness plan!
We have posed the question regarding DPNAs and facilities that need to be cleared and the OIG is seeking guidance from CMS. They report that CMS is supposed to be sending a memo relating to enforcement cases at any time, so be on the lookout.
Life safety inspections have been an issue brought up at the national level to CMS and we are awaiting guidance.
Fire inspections have been brought up to the OIG and we are waiting for guidance. The IG expressed that they are aware there are things they aren’t able to hold facilities accountable to during this time due to circumstances.
The question was posed whether it is advisable to close off a room for 24 hours before cleaning after a resident with possible COVID-19 is sent to the hospital. As long as the room is cleaned with a product approved for corona viruses, this is sufficient.
INVOLUNTARY DISCHARGE FOR NON-PAYMENT
Our industry should show great restraint in discharging residents for non-payment at this time. It is also believed that Medicaid applications may be delayed due to family members not being able to gather paperwork due to restricted access. If you have a resident who is facing involuntary discharge for non-payment, please contact Sherry Culp at firstname.lastname@example.org or 859.277.9215.
MEDICARE PART A 3-DAY HOSPITAL STAY & SPELL OF ILLNESS WAIVERS
As you know, CMS has released a national blanket waiver of the 3-Day Stay and the Spell of Illness. Blanket means these waivers apply to all states and all SNFs – no waiver requests are needed. To view the waiver, click here and to view CMS detailed billing guidance under the waivers, click here.
The AHCA team understands the complexity and risk associated with these waivers but need additional time to release more detailed and concrete guidance. Rest assured, the KAHCF team will issue this information as soon as this becomes available from AHCA.
MONITORING FOR SIGNS & SYMPTOMS
Per the OIG, it is recommended that all residents’ vital signs be monitored at least once every shift. We recommend developing a policy that requires frequent/regular temperature checks of both residents and staff throughout the day. See below in Staffing for a specific piece of guidance.
We are hearing more and more instances of individuals developing severe symptoms in a matter of hours.
According to the Centers for Disease Control, the most common symptoms of COVID-19 are fever, cough and shortness of breath, which may appear 2-14 days after exposure.
If you experience any issues with non-emergency transportation of residents during this time, please notify us at email@example.com.
NURSES (FROM THE KENTUCKY BOARD OF NURSING)
- Patient abandonment: The KBN has prepared this FAQ regarding this topic due to questions coming in from nurses and employers.
- Provisional Licenses
- After graduation and after the individual applies for the exam, they will be granted a provisional license
- Due to the unavailability of criminal background checks, these will not be done at this time
- Individual won’t be issued a permanent license until a criminal background check is completed
- The day before the provisional license expires, a notice will be sent to the email address that the KBN has on file (and the provisional address will be renewed if the state of emergency persists) - so individuals will need to make sure address on file is accurate
- Reinstatements, Un-Retirements & Endorsements for Nurses from Other States
- Individuals will need to fill out an application form and take a jurisprudence exam
- They will be issued a work permit for 6 months that may be extended
- If they would like it to be converted to a permanent license, a criminal background check will need to be completed
- Out of State Registry
- During the duration of the current state of emergency related to COVID-19, the Good Samaritan Act of 2007, KRS 39A.350-366, and KRS 314.101(1)(a) authorize the KBN to create a registry and authorize practice in the Commonwealth of nurses and board certified dialysis technicians who are not otherwise licensed to practice in Kentucky and who do not hold multistate practice privileges under the Nurse Licensure Compact but who are currently licensed and in good standing in another state. The Kentucky Registration for Emergency System for Advanced Registration of Volunteer Health Practitioners is applicable to both paid and unpaid positions. More information can be obtained here.
OMBUDSMANS' INFORMATION REQUEST
As communicated on Friday, we are aware of the Ombudsmens’ request for residents’ and family information. We have received several questions about this request, such as: How often is “routinely provide” when referring to providing this information? What is the Ombudsman’s Office doing with this information? What are they going to require facilities do once the information is provided?
Sherry Culp provided a Facts and questions regarding LTC Ombudsman services and requests for resident census and resident and family contact information memo
Please check here for updated OSHA information and regulations relating to COVID-19.
We’ve been made aware that, in some cases, hospital-based phlebotomists and certain therapists aren’t willing to enter into facilities even with orders. This issue was addressed on the OIG Huddle Call. IG Mather advised that he will remind the KHA of their duties. DAIL Commissioner Victoria Elridge advised that guidance has been issued by the OIG and distributed by the Kentucky PT, OT, speech and resp therapy associations to therapists that they must continue services from IG; therapies need to continue when medically necessary.
Effective with CMS’ approval of Kentucky’s 1135 waiver on March 25, 2020, PASRR screening for Level I and Level II were waived for 30 days. According to the waiver, “Pre-Admission Screening and Annual Resident Review (PASRR) Level I and Level II Assessments have been suspended for 30 days. Section 1919(e)(7) of the Act allows Level I and Level II assessments to be waived for 30 days. All new admissions can be treated like exempted hospital discharges. After 30 days, new admissions with mental illness (MI) or intellectual disability (ID) should receive a Resident Review as soon as resources become available. Additionally, please note that per 42 C.F.R. §483.106(b)(4), new preadmission Level I and Level II screens are not required for residents who are being transferred between nursing facilities (NF). If the NF is not certain whether a Level I had been conducted at the resident's evacuating facility, a Level I can be conducted by the admitting facility during the first few days of admission as part of intake and transfers with positive Level I screens would require a Resident Review. The 7-9-day timeframe for Level II completion is an annual average for all preadmission screens, not individual assessments, and only applies to the preadmission screens (42 C.F.R. §483.112(c)). There is not a set timeframe for when a Resident Review must be completed, but it should be conducted as resources become available.”
PERSONAL CARE HOMES
Kentucky Protection & Advocacy and the Administration on Intellectual and Developmental Disabilities, Administration for Community Living, U.S. Department of Health and Human Services has forwarded an easy guide to use at your facility to address COVID-19. Please click here to download the "COVID-19 Information By and For People With Disabilities."
PSYCHOSOCIAL NEEDS/ALLOWING PACKAGES
Per the OIG, contrary to prior guidance, it is now recommended that facilities not accept packages (food or otherwise) from family or community members with the exception of communication devices (which must be wiped down prior to being given to resident) and donations of PPE. It is recommended that you amend or create a policy around this for your facility.
At this time, according to the CDC, there is no evidence that the virus that causes COVID-19 can spread to people from the skin or fur of pets. There is also no evidence that animals are a source of COVID-19 in the United States. If you or a staff member at your facility wish to bring a dog into the facility for the psychosocial needs of your residents, it is acceptable at this time. But please be mindful that the animal will likely be travelling from resident to resident. It is advisable - even though there is no evidence of spread via fur, that you take precautions and wipe the dog down and have residents wash their hands immediately after handling.
AHCA/NCAL has developed a website that encourages and facilitates people caring social media messages of support for our nursing home and assisted living residents. Please visit here for ideas and share a message of support. #carenotcovid
CMS has been consulted regarding food practices but due to the fact the virus can live on surfaces and CMS is restricting visitors, the facility should consider restricting families from dropping off outside items at this time. It was suggested that facilities implement a policy related to COVID-19 restrictions and address this to that policy. The state ombudsman has been informed.
For facilities within Jefferson County, the official process to request PPE:
- Complete the attached resource request form with type and quantity of materials requested. (Make sure you fill out the facility in box #7 and phone number in box #13)
- Complete the attached status chart.
- Submit these attachments to IMTLogistics@louisvilleky.gov. (Please note: given limited supply, requests may not be filled in full. All requests submitted will be prioritized based on modeling surrounding need and capability to respond.)
- Once order is approved for pick-up, you will be notified by email with instructions and a map of the pick-up location. *Only those with a copy of approved email with them and on file at the POD location will be loaded.
For Jefferson County: Please see this handout from the Louisville Metro Public Health & Wellness COVID-19 Unified Command for Prioritization of PPE by Tier Levels.
Click here for printable instructions and forms from Louisville Metro Public Health & Wellness.
Attached is a template for your facility to use in your community to call for donations of personal protective equipment (PPE).
The process for securing and expressing the need for additional PPE is ever-changing due to the extreme shortage. The latest information we’ve received is that you should continue to work with your local Healthcare Coalition.
According to our OIG huddle calls, additional N95 masks won’t be in for 7-8 weeks. We are in CRISIS standards of care with regard to PPE! Based on the current COVID-19 situation and availability of personal protective equipment (PPE), CDC has issued updated conservation recommendations. For the most updated guidance from the CDC on acceptable ways to conserve your PPE, please click here or here. However, you must provide access to your staff if PPE is available!
Betty Shiels (University of Louisville, Emergency Preparedness) provided resources for our members regarding PPE conservation, re-use and the utilization of other materials. Please review and use this information to prepare for a worst-case situation in which you have an area outbreak, hospital surge & overflow, and run out of PPE.
KAHCF/KCAL inquired with the OIG about utilizing CMP funds for PPE. Jackie Aitkin advised that there is a portion of the CMP fund set aside for emergency funds ($3.8M) and that a letter from Kentucky is already being looked at in Baltimore. However, a new letter will be submitted on behalf of all Kentucky counties seeking additional CMP funds for PPE.
The question was posed whether facilities can reuse homemade cloth masks. Per the OIG, it is recommended that facilities refer to CDC guidance. Homemade cloth masks or other types of homemade masks (bandanas, vacuum bags, etc.) are only to be used if you no longer have approved PPE available.
For updated guidance from the CDC on acceptable ways to conserve your PPE, please click here or here.
We received an inquiry about how facilities should code “isolation” on MDS due to the mandate to limit the movement of residents around the building (realizing it is impossible to restrict all movement unless residents are confined to their rooms). The response from AHCA was that CMS has not issued any clarification on this issue and the MDS manual has not been updated to reflect any changes.
CGS recently sent an update that cost report deadlines have been extended. To see the CGS alert, click here. Staff is checking with the Department for Medicaid Services to see if Medicaid cost reports will be delayed as well. Providers will be notified once this has occurred.
DCBS Offices Closed for Appointments
Yesterday, the Association was informed that the DCBS office closures due to COVID-19 may not have been widely communicated to providers. Due to the COVID-19 National Health Emergency, a representative with the Department for Medicaid Services informed the Association that all DCBS offices are closed to foot traffic. All re-certifications are extended for three months beginning in March. If there are new applications to be submitted for long term care – there will be no face-to-face review for Level of Care – they should be submitted on-line or they can be mailed in.
On March 19, the Centers for Medicare & Medicaid Services (CMS) posted an update to its Frequently Asked Questions (FAQs) on the Medicaid.gov website to aid state Medicaid and Children’s Health Insurance Program (CHIP) agencies in their response to the 2019 Novel Coronavirus (COVID-19) outbreak. CMS is taking this action to continue its efforts to protect the health and safety of providers and patients, including those who are covered by Medicaid and CHIP.
You can find the updated FAQs by clicking here. These FAQs, and earlier CMS actions in response to the COVID-19 virus, are part of the ongoing White House Task Force efforts. To keep up with the important work the Task Force is doing in response to COVID-19, click here. For information specific to CMS, please visit the Current Emergencies Website.
Regarding Medicaid eligibility, Gov. Beshear stated yesterday that the “Department for Community Based Services (DCBS) will extend certification periods for all recipients of all public assistance programs (including Medicaid and State Supplementation) for three months. Those households whose certification periods end in May will automatically be extended to August, June to September, and so on.”
Visit the Benefind website here or call the DCBS call center at 1-855-306-8959. For Medicaid only, call the Kentucky Healthcare customer service line at 855-459-6328 or contact an application assister through the Kentucky Health Benefit Exchange website here.
Executive Orders and Regulatory Directives
RESIDENTS LEAVING THE FACILITY
According to the OIG, facilities can discourage, but are unable to prevent residents from leaving the facility without an executive order stating this. If a facility has residents expressing fear due to other residents leaving and returning, facility administrators should contact the OIG’s office at (502) 564-2888. This, in turn, will allow the OIG to communicate the need for such an order for a non-medical leave ban for residents of facilities.
With facilities moving residents in order to create a designated isolation wing or area for suspected or confirmed COVID-19 or any respiratory illnesses, the following question arose: if a resident expresses a desire not to move, does the safety and protection of all residents in this situation trump the individual resident’s rights?
The answer, according to the OIG, is yes. Moves to provide for isolation at this point are necessary. Please ensure you are documenting all efforts made to ensure resident’ comfort with unwanted moves.
Activities such as smoking that are routine and comfort-giving for residents should not be suspended during this time. However, it is advised that only a couple residents go outside to smoke at a time to allow for social distancing. Facilities should develop policies and procedures that incorporate good practices such as social distancing.
PERSONAL CARE ASSISTANTS: Kentucky Inspector General Adam Mather has put out new guidance and allowances for personal care assistant. Please see here. Or visit the OIG webpage and click on Personal Care Assistant Information.
For staff members who show signs or symptoms of COVID-19, the OIG advises there are no recommendations. This would be a company policy.
For asymptomatic staff who have been “exposed” to COVID-19, the OIG/DPH recommends that their temp be taken 3 times during each shift. It limits the workforce too much for them to be off work and in self-isolation when they are asymptomatic.
What is “exposure”? If staff has been wearing appropriate PPE and they discover they’ve been treating a COVID+ resident, they have not been exposed. The Kentucky DPH advises that staff members have to be closer than 6’ for longer than 20 minutes without proper PPE in order to be “exposed.” Remember to update your policies.
Staff should work in designated units and be breaking/eating lunch with those co-workers to avoid cross-contamination.
A request has been made for Kentucky to consider issuing letters for facilities and employees stating they are “essential businesses” and/or healthcare employees like other states are doing. The OIG recommends printing off letters with Governor’s orders from the website, but says this is unnecessary and these letters are not needed here in Kentucky.
For employees returning to work, see this CDC guidance.
- We are aware the KARES system is down. However, the OIG advises that the Kentucky State Police are available to do background checks:
- Here’s a link to the form that employers must use to secure a KSP background check.
- Also, this form is specific to LTCFs.
- As always, you can use a private vendor or the Kentucky Administrative Office of the Courts.
For Kentucky telehealth questions or resource needs, check here.
The Centers for Medicare & Medicaid Services (CMS) has broadened access to Medicare telehealth services so that beneficiaries can receive a wider range of services from their doctors without having to travel to a healthcare facility. These policy changes build on the regulatory flexibilities granted under the President’s emergency declaration.
For more information, please refer to the CMS.gov Medicare Telemedicine Health Care Provider Fact Sheet here.
We believe 60 day visits would be able to be done via telemedicine under this new flexibility as it applies to new patients, but the OIG is confirming.
These labs have had their results confirmed by an accredited laboratory such as the Department of Public Health Lab or CDC:
University of Louisville
University of Kentucky
Out of State- Charleston Area Medical Center (CAMC)
Here is a link to an FDA site with general information regarding testing and locations.
FDA Alerts Consumers About Unauthorized Fraudulent COVID-19 Test Kits
At this time, the FDA has not authorized any test that is available to purchase for testing yourself at home for COVID-19. If you are aware of fraudulent test kits for COVID-19, please report them to the FDA. To read the full press release, please click here.
The OIG recommends telehealth when possible for therapy, but asks that best clinical judgment is used and documented.
VISITATION RESTRICTION/ACTIVITIES/SCREENING & UPDATED END OF LIFE CLARIFICATION
Are home health workers permitted in assisted living and on a campus that is a CCRC? Per the KY OIG/DAIL, facilities are advised to use as much telehealth as possible. This should be evaluated on a resident to resident basis, as you don’t want permanent loss of function, but this needs to be balanced with resident safety. Document your efforts to keep your facility safe.
For families that need to be trained for resident discharge, it is recommended that you use alternate forms of communication v. in-person instruction, such as Skype & Zoom (deemed HIPAA compliant), and written instructions.
Screen everyone entering the facility - every time. Period. Please use this screening form for anyone entering your facility.
What is “exposure”: If staff has been wearing appropriate PPE and finds out treating COVID+ resident, they have not been exposed. Kentucky DPH is telling people staff has to be closer than 6’ for longer than 20 minutes. Develop guidelines.
The question was posed to the OIG whether CHFS is comfortable with lab and therapy staff working in multiple facilities. The OIG stated that he is unable to take a stance on this and recommends appropriate screening.
Hospice providers are considered essential to care for residents. Please continue to allow them access, but remember to screen them as you would any other visitor.
As you know, CMS issued guidance regarding restricting all visitor access from its facilities as the nation works to combat and limit the spread of COVID-19.
What is the definition for end of life for the purposes of visitation?
It is recommended that you defer to the patient's attending Physician, APRN or PA in consultation with the facility caregiving team when making the decision to call in the family. This is the procedure today and should continue to be the procedure. Please defer to that team for making the decision. Providers should notify family several days, up to one week in advance or when a substantial change of condition occurs. Providers should not wait until active dying.
Should first responders also be screened? What if they refuse?
Yes. Per CHFS/OIG first responders - like everyone entering your facility - must be screened (at the very least, temp taken and signs/symptoms questions answered). If a crew refuses to be screened, please
immediately email firstname.lastname@example.org and send the EMS/ambulance company name and name of first responder. We will communicate this through the proper channels.
Also, if able and appropriate, it is recommended that you meet first responders near the front door of your facility with distressed resident during this time in order to minimize response time and facility exposure.
As COVID-19 continues to develop, many businesses are experiencing layoffs while others are ramping up hiring efforts. To continue supporting Kentucky businesses and citizens in these challenging times, the Kentucky Chamber will be working in partnership with the state government by connecting those experiencing job loss to industries across the state currently in need of talent.
The Kentucky Chamber Workforce Center staff will work with employers looking for talent due to surges experienced with COVID-19. Then, they will work with Kentucky's Workforce and Education Cabinet and Career Centers across the state to identify talent currently experiencing job loss due to COVID-19.
In the past week, an unprecedented number of unemployment claims have been filed. So, how can you help? If you have an employment opportunity, visit here to fill out information on your facility so they can help recruit candidates to your team! This effort is a public service and of no costs to the employer or citizens of Kentucky. KAHCF/KCAL strongly urges you to take advantage of this process.
COVID-19 Screening Checklist for Visitors and Employees.
Families First Coronavirus Response Act: Media Materials
KAHCF/KCAL Managing A Case of COVID-19 in a Long Term Care Facility Handout. AHCA/NCAL document on communication after a confirmed COVID-19 case.
At this time, Kentucky does not have any mandatory curfews or travel restrictions, in the event that this does occur, please see this template emergency letter to your local law enforcement officials explaining the need for healthcare delivery services.
For Personal Care Homes - Kentucky Protection & Advocacy and the Administration on Intellectual and Developmental Disabilities, Administration for Community Living, U.S. Department of Health and Human Services has forwarded an easy guide to use at your facility to address COVID-19. Please click here to download the "COVID-19 Information By and For People With Disabilities."
Gov. Beshear directed the state nursing homes and other long-term care facilities to stop taking visitors. We advise that you immediately stop doing so and follow the guidance provided.
For your convenience, KAHCF/KCAL has designed a sign (approved by the Office of Inspector General) that your facility can post to alert visitors to this change. Click here to download.
Also attached is a form letter you can modify to fit the needs of your facility to notify residents and family members of this change.
We have received a visitor screening toolkit from our Florida affiliate and have modified it for your facility. This toolkit includes a checklist, letter to families and residents, and posters to hang up in your facility. To download the toolkit, please click here.
President's Alert on COVID-19 Communications
Due to the unknown length of time the COVID-19 pandemic will potentially affect Kentucky long-term care residents and communities, the Kentucky Association of Health Care Facilities/Kentucky Center for Assisted Living (“KAHCF/KCAL”) has decided to refrain from filling your email inbox with daily COVID-19 updates.
That being said, this issue is still of the upmost importance. Therefore, the Association is taking the following steps to keep our membership informed:
KAHCF/KCAL is attending regular “OIG Huddle meetings,” which have been called by the Office of Inspector General and includes the Inspector General, OIG staff, the state ombudsman, LeadingAge, KSLA, and the Department for Aging and Independent Living. The first OIG Huddle meeting was conducted yesterday and there is one scheduled for today.
KAHCF/KCAL had a conference call with the Department for Public Health (“DPH”) on Tuesday along with other stakeholders. DPH will not commit to regular calls but if a call is held, we will let the Membership know if new information is provided to us.
All COVID-19 communications will be sent on Friday afternoon UNLESS we need to communicate an URGENT COVID-19 message to the membership. If an urgent message is needed, we will send it as soon as we receive the information and determine (to the best of our ability) that it is accurate and useful.
Finally, the association has created a new email address, COVID19@kahcf.org for all communications, questions, concerns related to COVID-19. If we are able to answer your questions, we will try to do so within one business day. If the question or concern is something that we need additional guidance on, we will bring it up at the OIG Huddle meeting and get back to you as quickly as possible. All other membership questions and concerns can be communicated by email or calling a KAHCF/KCAL staff member.
Activities/Social Interaction Ideas
Centers for Medicare and Medicaid Services
Federal Disaster Resources
Governor Beshear Executive Order - March 23, 2020 - Click here.
HealthPRO Heritage Communications Toolkit
Kentucky Board of Nursing
- The Kentucky Board of Nursing held a special board meeting to address COVID-19. Attached are the notes from meeting.
- FAQ Patient Abandonment By Nurses here.
- Lyft has many available resources for those seeking to provide help for their communities. They are seeking ways they can help health care companies and workers. Please fill this form out to send your ideas.
Society for Post-Acute and Long-Term Care Medicine
Work with Partners
Verify with your local hospitals and other facilities if you are aligned in planning and the actions necessary if a potential infection is identified.
Advance notification – If residents with potential infection need to be transported, it should be mandatory to alert the destination so they can advise precautions.