The Centers for Medicare & Medicaid Services (CMS) recently announced actions aimed at addressing the spread of novel coronavirus 2019 (COVID-19). CMS promulgates industry guidelines and standards applicable to all healthcare facilities participating in its programs, including hospitals and skilled nursing facilities nationwide. As part of its COVID-19 announcement, CMS published three memoranda providing background information on COVID-19 and CMS’s renewed focus on addressing its impact at healthcare facilities throughout the country.

Notably, CMS requires participating facilities to maintain policies and procedures to address infection control and prevent the spread of disease. With its recent announcement, CMS is directing Survey Agency Directors and Accrediting Organizations to focus their regular inspections of all participating healthcare facilities, including over 15,000 nursing homes, on infection control practices. In coordination with the Centers for Disease Control (CDC), CMS has stressed the importance of proactive measures to ensure and advance patient safety and reduce the spread of COVID-19.

Specifically, CMS mandates surveys for:

  • All immediate jeopardy complaints (a situation in which entity noncompliance has placed the health and safety of recipients in its care at risk for serious injury, serious harm, serious impairment or death or harm) and allegations of abuse and neglect.
  • Complaints alleging infection control concerns, including facilities with potential COVID-19 or other respiratory illnesses.
  • Statutorily required recertification surveys (Nursing Home, Home Health, Hospice, and ICF/IID facilities).
  • Any revisits necessary to resolve current enforcement actions.
  • Initial certifications.
  • Surveys of facilities/hospitals that have a history of infection control deficiencies at the immediate jeopardy level in the last three years.
  • Surveys of facilities/hospitals/dialysis centers that have a history of infection control deficiencies at lower levels than immediate jeopardy.

Training and resources should be devoted to ensure staff awareness of precautionary and preventative measures. Facilities should be mindful of patients with risk factors for the virus and implement measures to monitor and guard against the potential spread to other patients, providers, or visitors. Additional considerations related to patient discharge are also addressed. For instances where COVID-19 is suspected and/or identified, prompt triage and isolation of infectious patients is essential to limit unnecessary exposure. Many states have local Boards of Health that must also be notified. CMS warns that facilities with deficiencies are subject to enforcement actions ranging from requests for correction plans to termination.

Prepare Your Facility – What You Should Do Now

In light of CMS’s announcement, centers should take this opportunity to review their infection prevention and control policies and procedures for droplet precautions among residents and staff. Prepare your staff with refreshed training on proper hand hygiene and personal protective equipment, and their responsibility to stay home when sick. Reassure staff that it is a similar approach to closures due to weather emergencies – something they are more familiar and comfortable with.

Communication with residents and resident families is also critical. Centers should have a communication plan in place for how to quickly and accurately disseminate information to residents, resident families, and other responsible parties. Template letters, a dedicated “communication station,” and a designated “community liaison” are all effective preparation tools. Centers should also be prepared to handle media inquiries. Having a plan in place for the non-clinical aspects of an outbreak that can be quickly executed allows a centers’ clinical staff to focus on care and treatment and preventing further spread.

In addition to routine infection control measures, centers should implement more unique steps to minimize the risk of outbreak. “Handwashing” stations should be set up at all entrances with alcohol based hand sanitizers. If your center has a lobby bathroom for visitors, ask them to wash their hands before proceeding further into the facility for their visit. Post signs at the entrance instructing visitors not to visit if they have symptoms of respiratory infection. Finally, centers should educate families and visitors on the signs and symptoms of respiratory illness and encourage them to visit with loved ones through alternative means, such as telephone, Skype, or FaceTime.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.