KAHCF/KCAL Emergency Preparedness Contacts

COVID19@kahcf.org

 

KAHCF/KCAL COVID-19 Response Team

Betsy Johnson 
President


Ashlea Christiansen
Director of Regulatory Affairs

Wayne Johnson
VP of Finance


Press Contact

Emily Weber
Director of Communications

 

State Agency Contacts

Department of Public Health
Hotline: 1-800-722-5725
kycovid19.ky.gov

Clinical Call Center: 1-888-404-1539

Supervisor Resources
Staff Resources
Model Plan for Implementing Workforce Resilience Strategies

Gov. Beshear Facebook Page
Daily Briefings at 5pm EST
Daily Briefings Youtube Page
Gov. Beshear Press Releases
Team Kentucky Fund

To find your local testing center: visit here and find your county in the drop down menu

Federal Contacts

Center for Medicare and Medicaid Services (CMS)
Current Emergencies Website
COVID-19 Stakeholder Calls Podcasts & Transcripts
Guidance as of 4/2/20

Federal Disaster Resources

AHCA/NCAL

#CarenotCovid

Guide: Emergency Preparedness Requires a Communications Plan

Sample Letter to Residents & Families Re: Visitation

Sample Letter to Employees  


Other Resources

Norton Healthcare Post Acute Statewide Help Line
1-502-446-2680
877-435-7219
Flyer

Lift Up Lou

National Certification Council for Activity Professionals

C2 Strategic Communications

Alzheimers Association Hotline:
800-272-3900
Phone support group lines across KY

CDC Clinical Call Center: 770-488-7100
coca@cdc.gov
CDC COVID-19 Website

QSource
Helping to align facilities with CDC Guidelines
nhassist@qsource.org
423-202-2561

Kentucky Medical Director's Association

National Guardianship Association

Project N95

Altapure disinfectant

US Small Business Administration

Broad River Rehab COVID-19 presentation
HealthPro Heritage Toolkit

Lessons Learned from the Washington State Outbreak

Managing a Case of COVID-19 in a Long Term Care Facility

Strategies for Optimizing the Supply of N95 Respirators

NIOSH-Approved Particulate Filtering Facepiece Respirators

 

Executive Orders

4/9/20 - Dispensing of Pharmaceuticals
4/9/20 - Workers' Compensation
4/8/20 - State of Emergency
4/6/20 - Prohibition of Price Gouging
3/22/20 - Business Closure
3/16/20 - State of Emergency Relating to Unemployment Insurance Claims & Benefits
3/10/20 - Dispensing of Pharmaceuticals
3/9/20 - Relating to Insurance
3/6/20 - State of Emergency

KAHCF/KCAL stands by your side during this particularly challenging time. Visit this website daily for the latest information KAHCF/KCAL has to share about COVID-19. We have regular calls with the OIG, DAIL and DPH to seek answers for your most pressing COVID-19 related questions. Please send all COVID-19 related questions to covid19@kahcf.org so that we can appropriately channel and respond. It would be helpful to all organizations if questions are funneled through the association in order to assist all members. 

For weekly CMS, CDC, OIG, DAIL, DPH, AHCA/NCAL, and OSHA updates, please click our weekly updates on the side-bar.


May 29 Video Update


NEW!  Guidance for Long Term Care Employees Returning to Work (May 21, 2020). Read here.

NEW! Supplemental Guidance from the Cabinet for Health and Family Services regarding Long Term Care Admissions and Discharges. Read here.

NEW! Strategies to Mitigate Healthcare Personnel Staffing Shortages during the COVID-19 Pandemic. Read here.

NEW! Per the Cabinet memo dated April 9, 2020  (which allows providers to rely on the HHS 1135 blanket waivers during this time) ALL of the CMS blanket waivers listed here apply to Kentucky providers. 

 

Facility Testing Information - Click here

Available exclusively to AHCA/NCAL members is a COVID-Related Loss and Cost Calculator(login required). The purpose of this excel workbook is to offer a basic tool for members to assess allowable costs already reimbursed by pre-COVID payers, such as Medicare and Medicaid, and compare such reimbursement to shortfalls where grants and loans fill funding gaps.

 

Community 


 Hand Sanitizers
  • 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.

Consulting

  • For Louisville area: Craig Jennings is a former Regional Director of Operations for nursing homes and is currently available for consulting for business startups, operations, marketing, and workforce development. Attached is his resume.

 Technology

  • 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 nhoa@ombuddy.org. This will help them respond to concerns about access to communications.

PPE

  • Gordon Technologies, Inc. based in Louisville, KY is donating face shields with a quantity of under 100 (in Louisville). Any quantities over 100 are $2.10. Please visit  website for contact info and ordering.
  • 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 bhackbarth@healthy-ky.org or 502-552-3770.
  • Chandrika Srinivasun is sewing face masks for donation. Please contact her at lsvasan@twc.com.


Do you have any PPE you can donate to Kentucky's long term care facilities? 
Fill out a brief form on your supplies here and we will ensure it gets to providers.

*Donations only
*
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.

 

Advocacy


On April 24, 2020, KAHCF/KCAL, LeadingAge KY, and KSLA sent a letter to Gov. Beshear requesting civil immunity for elder care workers and providers during this time of crisis.

Rep. Andy Barr sent Secretary Alex Azar a letter on April 17, 2020 to request allocation of funding to skilled nursing facilities.

KAHCF/KCAL sent a letter to Gov. Andy Beshear on March 24, 2020  to request funding provided by the recent passage of the Families First Coronavirus Response Act. KAHCF/KCAL and LeadingAge Kentucky sent a follow-up letter to Gov. Andy Beshear on April 17, 2020 to address the denial of our request for the Medicaid rate add-on due to the COVID-19 pandemic.

 KAHCF/KCAL sent a letter to Secretary Alex Azar, Department of Health and Human Servicesregarding the Coronavirus Aid, Relief, and Economic Security Act and our request that part of the $100 billion allocated for health care providers be directed to skilled nursing facilities in the United States. 

KAHCF/KCAL also sent out a letter to be used to sent by Senate President McConnell to HHS Secretary Azar. 

   

FAQ's By Topic


ADMISSIONS/DISCHARGES/TRANSFERS

On April 21, 2020, the Long Term Care Task Force assembled by the Cabinet for Health & Family Services issued new guidance on long term care admissions and transfers of residents. On May 12, 2020, supplemental guidance was given. Read here.

In the memo, it states that a nursing home can admit a person diagnosed with COVID-19 and still under transmission-based precautions for COVID-19 as long as the facility can follow CDC guidance. If a nursing home cannot, it must wait to admit the person until the precautions are discontinued.

On March 31, KAHCF/KCAL collaborated with the Kentucky Hospital Association and LeadingAge to release a hospital transfer to SNF/NF tool. To access this new protocol, click here.

AHCA issued interim guidance to help skilled nursing facilities (SNFs) make decisions about accepting hospital discharges to SNFs during COVID-19 pandemic.

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 nhoa@ombuddy.org or 859.277.9215. 

  

ALTERNATIVE CARE SITES

Learn more from the CDC about the purpose of alternative care sites here.


ASSISTED LIVING COMMUNITIES

DAIL's  FAQ document

AHCA/NCAL guidance re: notifications for confirmed cases

Effective Tuesday, April 28, all assisted living facilities will be required to use two new tools to report COVID-19 related information. The Department for Aging and Independent Living (DAIL) along with the Office of the Inspector General (OIG) and the Department for Public Health (DPH) have created two survey reporting systems to capture all information related to COVID19.

The first reporting system will be done through SurveyMonkey. This survey will capture any NEW positives (residents and/or staff) and should be completed by 6:00pm DAILY:  https://www.surveymonkey.com/r/LBMVSDJ


This survey is to report DAILY NEW cases of COVID-19 in residents and staff and to report NEW COVID related deaths in residents and staff. For example, if you get two positive labs for residents on Sunday, you would report those on Sunday’s report, and then on Monday if you didn’t get any new cases you would report zeros on all of the reporting fields.

This survey should be completed daily, 7 days a week until you are told by KDPH to discontinue using it.

The second reporting system is done through Redcap. This is to be completed monthly. This survey will capture the total testing numbers: https://redcap.link/kycovidltcf


This survey should be done the 1st of every month (so this Friday)

This survey is used to report your TOTAL number of COVID tests done on residents and staff in March and April 2020.

The Number of Positive Results is your TOTAL for April (for both residents and staff)

The Governor’s office is trying to capture the total number of residents and staff at LTCF and other facilities (like AL and PC) that have been tested for COVID.  These numbers will also help us figure out the percentages of KY residents in these facilities that are positive and that have been tested.

When you complete the survey again on June 1st, you should only put your total number of tests for May 2020. (We are just doing March and April together because so many people were unsure how to complete it.)

This survey should be done monthly until you are told to stop using it.

DAIL staff are here to provide technical assistance when they call, so do not hesitate to ask questions. They will be verifying that you are submitting your reports so please make sure daily reports are completed.


On April 9, the Department for Aging and Independent Living ("DAIL") hosted a town hall webinar on providing COVID-19 Guidance regarding Assisted Living facilities.  Click here to review the presentation slides.  DAIL also shared a video from the CDC - Preparing Nursing Homes and Assisted Living Facilities for COVID-19


 

CARE PLANNING

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.

 

CARING FOR DECEASED 

POLST Paradigm

 

CELL PHONES

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.


DINING

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. 
 

 

DOCUMENTATION

Please be mindful of the need to carefully document the efforts that you have made to secure assistance, supplies, answer questions, and what steps you have taken to protect your residents. It is likely that lawsuits will be filed alleging abuse and neglect and your records will be subpoenaed. Ensure that you have complete and accurate records detailing the efforts that you and your staff have made. We know you are working incredibly hard to keep your residents safe. Make sure everyone knows this.

Law firm Husch Blackwell lays out some general steps for documenting activities and response efforts to be prepared for surveys and potential litigation. AHCA/NCAL also recommends working with your legal counsel to develop practices. This resource is available to AHCA/NCAL members (log in required). 

 

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!

 

ENFORCEMENT ACTIONS

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.

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.

ALL surveyors need to wear PPE when conducting a survey in the facility. If state or federal surveyors are unable to meet the Personal Protective Equipment (PPE) expectations outlined by the latest CDC guidance to safely perform an onsite survey due to lack of appropriate PPE supplies, they are instructed to refrain from entering the /provider, and obtain information necessary remotely, to the extent possible. Surveyors should continue the survey once they have the necessary PPE to do so safely. If a surveyor tries to enter your building without the proper PPE, please contact KAHCF/KCAL immediately.


 
ENVIRONMENTAL/CLEANING

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. The CDC has released new guidelines on how to clean your facility if someone with COVID-19 has been present. Please review and update your policies as necessary. 

Regarding Annual Sprinkler Inspections: Per CMS, “if you review 2011 NFPA 25 Chapter 5 for the requirements they might find that some of the inspections could be done by the facility maintenance staff. For example 5.2.1.1 sprinklers shall be inspected from the floor level annually.  Looking for corrosion, leakage, damage, dirt/lint/paint etc. You can access the codes here.

 

FEMA

We understand that many of you have received letters regarding FEMA reimbursement. To know if your facility is eligible, contact the following:

Jessica Mitchell, Kentucky Emergency/Management
Recovery Branch Manager 
100 Airport Road, 3rd Floor
Frankfort, KY  40601
Phone:  (502)-607-5762
Fax:  (502)-607-5740

FEMA will make the ultimate determination on eligibility, it can take months for the process, and there is no guarantee FEMA will actually pay out the money. When FEMA says to capture expenses, everything has to have evidence of expenditure, invoices for everything, staffing expenses by times for each staff person, evidence of overtime, actual proof of costs incurred, etc. Anything not totally justified and proven will be rejected. 


HOSPICE

AHCA/NCAL worked with National Hospice & Palliative Care Organization to develop joint guidance on the important role hospice plays during the spread of COVID-19 in nursing homes and assisted living.

 

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 nhoa@ombuddy.org or 859.277.9215. 

 

LEGISLATIVE UPDATE

 

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 DPH & OIG, it is not recommended that residents’ vital signs be monitored every hour because this increases the risk of exposure from staff entering the resident’s room so often. However, we have not been provided with guidance on exactly how often monitoring SHOULD take place other than per the OIG, “at least once every shift.” This would include temperature, blood pressure and O2. We recommend monitoring vital signs once per shift until/unless further guidance is provided. 

NON-EMERGENCY TRANSPORTATION

If you experience any issues with non-emergency transportation of residents during this time, please notify us at covid19@kahcf.org.

 

NURSES

From the Kentucky Board of Nursing

The Kentucky Board of Nursing passed the emergency regulation (201 KAR 20:225E) to allow the board to issue temporary work permits to nurses whose license has lapsed or who have retired. The temporary permit is good for six months and a criminal background check is required.

  •  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     

We are aware of the Ombudsman's 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

 

ORAL CARE
Developed by an oral health professionals work group, attached is a tips sheet addressing the oral health of residents during this pandemic.

OSHA INFORMATION

The Occupational Safety and Health Administration (OSHA) has issued two separate enforcement memoranda related to the use of respirators by healthcare and non-healthcare employers. This includes all long term care providers: skilled nursing, assisted living, and ID/DD providers. The memoranda address issues facing employers regarding the respirator shortage, giving employers limited relief from OSHA’s Respiratory Protection standard as a result from COVID-19.

Be Prepared - OSHA Requirements for PPE

  • We’ve learned that some members and other health care entities are receiving letters from OSHA regarding lack of PPE. AHCA/NCAL has consulted with its outside consultants who recommend preparing a plan with the following information: 
  • If you are running low on PPE, follow the CDC guidance and guidance from your local health department. 
  • Have a plan in place that deals with potential exposure to COVID-19 for employees, for example, what happens if a staff member has respiratory or other symptoms indicative of COVID-19 or tests positive with COVID-19. 
  • Communicate this plan to all staff often and have it available for staff to review.   

Recording workplace exposures to COVID-19 - Occupational Safety and Health Administration (OSHA) 

  • OSHA recordkeeping requirement at 29 CFR Part 1904 mandate covered employers record certain work-related injuries and illnesses on their OSHA 300 log. While this requirement exempts recording of the common cold or flu, COVID-19 is a recordable illness when a worker is infected on the job if the following are met:
  • Visit OSHA’s Injury and Illness Recordkeeping and Reporting Requirements page for more information.
     
  • NEW! AHCA/NCAL released four new resources on guidance from the Occupational Safety and Health Administration (OSHA) and the Centers for Disease Control (CDC) on critically low or unavailable Personal Protective Equipment (PPE). These new resources are applicable to all long term care providers. 
  • A document with updated guidance from OSHA on employer recording and reporting requirements for COVID-19.  

 

OUTSIDE SERVICES

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.

 

PACKAGES/FOOD

Facilities should develop their own policies regarding packages from the outside, keeping in mind that it is recommended that only necessities be permitted, and those be wiped down.

 Per the OIG we are not able to stop residents from ordering food from outside the facility. All you can do is encourage residents to practice hand hygiene after handling food packages, or perhaps put the food in/on a different plate/container and leave the potentially contaminated container outside of the facility.


PASRR GUIDANCE

 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.”

 

PPE

Requesting PPE by area: 
For facilities within Jefferson County, the official process to request PPE: 

  1. 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)
  2. Complete the attached status chart.
  3. 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.)
  4. 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.

During our most recent huddle, the state was unable to provide an update on PPE. Betty Shiels was able to inform us that, at this point, we as a nation are waiting for production to ramp up both domestically and abroad. We have reached “crisis levels of care” with regard to PPE. She reported that the Joint Commission will soon be issuing guidance that staff may bring their own PPE into the workplace, and the CDC guidelines allow for this as well.  We strongly encourage you to communicate with your team members and encourage their safety during this time. If you are out of PPE, allow them to bring home-made masks and other PPE for their comfort and safety. 

  • If surveyors attempt to enter your facility without proper PPE, please immediately notify covid19@kahcf.org. Per CMS guidance, this should not be occurring. 
  • Please see the following presentation from the National Emerging Special Pathogens and Education Center formerly the National Ebola Training and Education Center (NETEC)

COVID-19 PPE WEBINAR - EXTENDED USE, REUSE, AND INNOVATIVE DECONTAMINATION STRATEGIES

FOR NORTHERN KENTUCKY FACILITIES: If you need assistance with supplies reach out to Stella Barber with the Disaster Preparedness of NKY.  Stella’s contact info is below.
Stella Barber
Disaster Preparedness Coordinator
Northern Kentucky Health Department 
8001 Veterans Memorial Drive, Florence, KY 41042
Office: 859-363-2036 |  Fax: 859-578-7871 
stella.barber@nkyhealth.org

Requesting PPE - DPH Guidance:
We have received new guidance from the Kentucky DPH regarding how to request PPE. Any agency, business or facility that is requesting the following types of PPE must report the following data daily by 10:00am (EDT) at https://tinyurl.com/kyppestatus   

In your report, you must state:                                                              

  • Current Amount on Hand
  • Current Usage Rate                                                   
  • Estimated Days Left in Supply                                                                                   

You should use the following triggers to determine when to request PPE from the SEOC:                                                       

  • 7 days of inventory or greater: No resource request should be submitted to the SEOC.
  • 4-6 days of inventory: Submit requests for needed PPE, not to exceed a 7-day supply.           

3 days or less of inventory: Coordinate with County EMA/LHD to check resource request status.

The DPH has again reiterated how important this CDC resource is. We were told that there have been reports by EMS workers and DPH employees of staff in facilities improperly utilizing PPE. We strongly recommend that you review the following resources with your staff, and recognize that we could move from “critical shortage” and PPE conservations, back up to standard procedures quickly.

Requesting PPE from FEMA:
FEMA has launched an online personal protective equipment exchange seeking to connect those selling PPE with those looking to buy it.  Anyone can log in following the directions shown below, you need to have Adobe Connect installed on your computer but the software is free and you should be automatically prompted to download it when you visit the link below:

1.      Log-in with your name and company on the dashboard
2.      Follow instructions on completing either the need or sell section.
3.      Contact individuals via their provided contact information.
4.      When you log out of the Dashboard, your information remains, but no one can connect with you in the Dashboard. Providing your contact information is important.

PPE Burn Rate Calculator - Mobile App
The Personal Protective Equipment (PPE) Burn Rate Calculator is now available as a mobile app. Facilities can use the NIOSH PPE Tracker app to calculate their average PPE consumption rate or “burn rate.” The app estimates how many days a PPE supply will last given current inventory levels and PPE burn rate. For the excel version, please visit the CDC website.

Guidance on wearing PPE:
According to Governor Beshear’s Tuesday, April 7 evening briefing and the KY Department for Public Health, all nursing home residents in Kentucky should wear face masks if they leave their rooms. CDC guidance had previously indicated that staff members wear PPE.  However, moving forward, it is recommended that residents stay in their rooms as much as possible. If there is a specific reason they should leave the room, they need to wear a mask.If someone enters the resident's room to provide care, the resident should wear a mask while that person is in the room. 

Click here for a sample donning/doffing policy based on CDC guidelines that you can adapt to your facility and use to educate your staff.

Homemade masks:

Can facilities 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. If you find your facility in this position, here is guidance from the Minnesota Department of Health that is very helpful. 

 

REIMBURSEMENT/CODING

 
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. 

 
RESIDENTS RIGHTS
Here are recommendations to help you address when a resident wants to leave the building to go into the surrounding community and then return. This could introduce COVID-19 into the building and endanger others. Our recommendations include communicating with the resident and family, requiring isolation, and contacting the ombudsman and the local health department.
42 CFR 483.12(b)(5)(B) allows for up to 24 hours to report resident to resident abuse if no injury is noted. If an injury is noted, the report has to be made within 2 hours. It has come to our attention that, historically, Kentucky has interpreted the regulation to mean that even resident to resident incidents where no injuries occur have to be reported within two hours, which causes an incredible strain on staff, particularly with the workload as it is during the COVID-19 crisis. Remember to refer back to the actual language of the regulation and if you have any questions, don’t hesitate to contact us at covid19@kahcf.org. We have also notified the OIG that we have educated our members regarding this regulation.

 

SMOKING


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.
  

STAFFING

The OIG now needs to be notified if a staff member tests positive for COVID-19.  Please email Jackie.Aitkin@ky.gov
Please see CDC Guidance re: COVID Crisis Standards of Care for Staffing. It deals with Pandemic versus the KY standards developed for mass casualties.

KAHCF/KCAL has created a helpful resource to help you understand the different temporary waivers and the necessary associated training in Kentucky. These include Nurse Aide (SRNA), Personal Care Attendant, Feeding Assistant, and Method of Instruction. In this resource, you will find the necessary links to their website, specific details on each training, and the appropriate contacts.

The PCA waiver specifically states that the training can be offered regardless of a facility having been prohibited from providing other types of training. I believe this is because the PCA position/certification is new here in Kentucky and temporary during the COVID crisis. However, if your facility’s training program for any other position has been prohibited as part of a CMS penalty, you may still not provide that prohibited training.

We continue to receive many questions about staff returning to work after “exposure” to COVID-19. Please refer to the CDC guidance.

Background Checks:
We are aware the KARES system is down. However, the OIG advises that the Kentucky State Police are available to do background checks:
As always, you can use a private vendor or the Kentucky Administrative Office of the Courts.
We have been made aware that all of these methods are taking quite a while and we have reported this to the OIG.

Please see CDC Guidance re: COVID Crisis Standards of Care for Staffing. It deals with Pandemic versus the KY standards developed for mass casualties.

 

TELEHEALTH

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. CMS telehealth toolkit.

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.

 

TESTING

These labs have had their results confirmed by an accredited laboratory such as the Department of Public Health Lab or CDC:
LabCorp
Quest
University of Louisville
University of Kentucky 
Solaris
Lexington VA
Louisville-Metro Health Department 
Gravity
St. Elizabeth’s Hospital
Lexar Labs
 
Out of State- Charleston Area Medical Center (CAMC)
Here is a link to an FDA site with general information regarding testing and locations.

University of Louisville

  • You will find two documents related to COVID-19 testing via UofL. One document provides data on the steps of submitting a specimen for COVID-19 testing. The other is an agreement that outlines what UofL will provide and the cost per test. It is our understanding that CPT Code 87635 can be used by the facility to bill for the test. The facility is billed directly, not insurance.

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 clickhere.


THERAPY

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

It has come to our attention that some facilities are allowing residents to speak with family members through window screens. We STRONGLY recommend that this practice immediately stop. While we sincerely understand the emotional toll this separation is taking on residents and their families, the virus could potentially be passed through the screen, putting your residents and staff members in jeopardy.

The IG reversed their “animals are ok” guidance. We have heard a cat tested positive for COVID-19, so out of an abundance of caution, they’d prefer we not allow animals in facilities if they’ve not been living there full-time.

Per CMS guidance, surveyors must be wearing proper PPE in order to enter your building during this time. If there is an instance when a surveyor enters without PPE, please immediately notify covid19@kahcf.org

What is “exposure”? If your staff have been wearing appropriate PPE and finds out they have been 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 for this.

Screen everyone entering the facility. Every time. No exceptions.  Here is the most up to date screening tool. But be aware that often guidance comes out in the middle of the week prior to our Friday updates. Therefore, we recommend you continue to check our website for more up to date information. 

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.

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 covid19@kahcf.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.


WORKFORCE

 
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. 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.

 

Materials


COVID-19 Screening Checklist for Visitors and Employees. Maine Health Care Association Screening Infographics

At this time, Kentucky does not have any mandatory curfews. In the event that this occurs, please see this template emergency letter to your local law enforcement officials explaining the need for healthcare delivery services. 

 

Resources


CDC Resources

Centers for Medicare and Medicaid Services

  • CMS Waivers and COVID-19 Response - Please see the attached presentation by the Principal Deputy Administrator for Operations of CMS, Kimberly Brandt.
  • White House/CDC Announce New Guidance for how Critical Employees Can Return to Work
  • Dear Clinician Letter - CMS posted a letter to clinicians that outlines a summary of actions CMS has taken to ensure clinicians have maximum flexibility to reduce unnecessary barriers to providing patient care during the unprecedented outbreak of COVID-19
  • CMS COVID-19 FAQs
  • CMS Long Term Care Infection Control Self-Assessment Tool Checklist
  • COVID-19: New ICD-10-CM Code and Interim Coding Guidance
  • The targeted infection control survey 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.
  • 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 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 to MDSCodinganswers@cms.hhs.gov. 

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.
  

Kentucky Protection & Advocacy

Signage

Society for Post-Acute and Long-Term Care Medicine