A Breakdown Of CMS' Reopening Guidance For Skilled Nursing Communities

I’m so proud of how our local and national activities groups have stepped up to help senior care providers navigate the pandemic. They’ve made it a priority to produce continuing education content and share best practices so that we can all get through this together. That said, I thought you might find the information shared during a recent session hosted by the National Association of Activity Professionals (NAAP) valuable.

The live session was titled “Breaking down the Guidance from CMS to open SNFs across the United States.” Presenters Alisa Tagg, NAAP Association Director, and Vanessa Emm, NAAP Director of Operations, did a really nice job of making the Centers for Medicare & Services (CMS) community reopening guidance digestible and easy to understand.

The speakers prefaced their presentation by stressing that even though skilled nursing facilities are beginning to open, they are moving at a slower pace than the rest of the state. They said it’s also important to keep in mind that different facilities will enter these phases at different times depending on the severity of outbreaks of COVID-19 in their community.

These phases set forth by CMS in their Opening Up America Again plan were created to eliminate elevated risks for additional outbreaks of the novel coronavirus within communities, a sector that, as you well know, has proven to be severely impacted.

Each phase of the plan must be completed before moving onto the next phase. Phase 1 and 2 must be observed for a minimum of 14 days, and phase 3 must be observed for a minimum of 28 days. Before relaxing any restrictions and moving through the phases, facilities should ensure they have adequate staffing, access to testing, PPE and essential cleaning and disinfection supplies. Most importantly, communities should not advance through the phases until all staff and residents have been tested and the appropriate actions are taken based on the results.

CMS recommends that states continue to survey nursing homes that have had significant COVID-19 outbreaks throughout these various stages to ensure they are remaining vigilant and preventing further transmission.

The following actions are required during all three phases:

• All staff must be tested weekly
• All people entering the building and all staff must be screened at the start each shift. This includes temperature checks, symptom and exposure checks, and ensuring that a face covering is worn
• All staff must continue to wear proper PPE that meets CDC guidelines when interacting with residents (if available)
• All residents must be screened at least daily via temperate checks and questions and observations about COVID-19 symptoms
• All residents are still tested if any individual in the building displays symptoms consistent with COVID-19 or if a staff member has tested positive for COVID-19. Weekly testing then continues until all residents test negative
• Each community must provide a dedicated space to cohort and manage care for residents with COVID-19 as well as a plan to manage new/readmissions with an unknown COVID-19 status and residents who develop symptoms

Here are the main differences and requirements for each phase:

Facilities may entire phase 1 with the proper precautions in place and no cases of COVID-19.

What is permitted during this phase:

• Communal dining for residents that are COVID-19 negative and asymptomatic with 6 feet of social distancing

What is still prohibited during this phase:

• Visitors, except in compassionate care situations (all exceptions must practice hand hygiene, maintain social distancing and wear a face covering during the visit)
• Non-essential healthcare personnel
• Group activities
• Non-medically necessary trips outside of the buildingIf a trip is necessary, the resident must wear a face covering and the facility must share their COVID-19 status with the transportation service & person they are seeing for the appointment

After 14 days of no new COVID-19 cases in the building, providers can move to phase 2.

What is permitted during this phase:

• Entry of a limited number of non-essential healthcare workers/contractors (to be determined by the facility). All must be screened before entry, practice hand hygiene, social distancing and wear a face covering
• Group activities and outings in groups of 10 may begin for COVID-19 negative or asymptomatic residents only. All must practice proper hand hygiene, wear face masks and practice 6 feet of social distancing at all times
• Outings may begin that are medically necessary such as physician appoints. All residents must wear face masks outside of the building
• Communal dining for residents that are COVID-19 negative and asymptomatic with 6 feet of social distancing between all residents

What is still prohibited during this phase:

• Visitors are generally prohibited except in compassion care situations (all must practice hand hygiene, maintain social distancing and wear a face covering during the visit)

If the facility has no new cases or COVID-19 positive residents for 28 days, providers can enter Phase 3.

What is permitted during this phase:

• Visitors, volunteers, non-essential healthcare workers and contracted vendors can come into the building. All must be screened before entry, practice hand hygiene, social distancing and wear a face covering
• Group activities and outings in groups of 10 may begin for COVID-19 negative or asymptomatic residents only. All must practice proper hand hygiene, wear face masks and practice 6 feet of social distancing at all times
• Outings that are medically necessary such as physician appointments. All must wear face masks out of the building and share their COVID-19 status with the transportation company
• Communal dining for residents that are COVID-19 negative and asymptomatic with 6 feet of social distancing between all residents
• Standard State Surveys will resume during this phase. For more information on the surveys that will be performed during each phase of the reopening, see the CMS memo here

It will be a long road back to business as "normal" for senior care communities, but I'm confident we will get there by following the proper guidelines CMS has put in place. One thing is clear. The pandemic is shaping the future of long-term care and senior living. The industry has made strides in areas like infection control, individualized resident engagement programs and communication – both between management and staff and with the families we serve.

I’ve been particularly impressed at the way I’ve seen communities provide that person-centered care that we all strive for. The COVID-19 crisis has certainly brought to light just how important staffing is to achieve our mission and many are taking note of the significant challenges our industry faces in this area. Our staff are the backbone of our communities and we must continue to support them through this pandemic and beyond. I can’t wait to see the programs providers put in place post-pandemic to recruit, engage and retain these essential workers. And something tells me that technology will play a huge part in that.