The Centers for Medicare and Medicaid Services (CMS) issued guidance to assist State and local officials in reopening nursing homes safely (press release, FAQs). The guidance is intended to provide steps nursing homes and communities should take prior to relaxing restrictions.
Criteria for Relaxing Certain Restrictions and Mitigating the Risk of Resurgence – CMS encourages State leaders to collaborate with State survey agencies, and State and local health departments to decide how the following criteria should be implemented in their States. CMS recommends that decisions on relaxing restrictions be made after review of the following facility-level, community, and State factors:
- Case status in the community – State-based criteria to determine the level of community transmission and guides progression from one phase to another.
- Case status in the nursing home(s) – Absence of any new nursing home COVID-19 cases among residents and staff.
- Adequate staffing – No staffing shortages and the facility is not under a contingency staffing plan.
- Access to adequate testing – The facility should have a testing plan in place based on contingencies informed by the Centers for Disease Control and Prevention (CDC). This should include the capacity for all residents and staff to have a single baseline COVID-19 diagnostic test.
- Universal source control – Residents and visitors wear a cloth face covering or facemask. Additionally, all visitors should maintain social distancing.
- Access to adequate personal protective equipment (PPE) for staff – Contingency capacity strategy is allowable and all staff are to wear PPE when indicated.
- Local hospital capacity – Ability for the local hospital to accept transfers from nursing homes.
Recommended Nursing Home Phased Reopening for States – CMS also provides a recommended nursing home phased reopening process, which coincides with the Trump Administration’s Opening Up America Again plan. CMS notes that because COVID-19 poses an elevated risk to nursing home residents, the agency recommends additional criteria for advancing through the phases of reopening. These include:
- Nursing homes should not advance through any phase or relax any restrictions until all residents and staff have received a base-line COVID-19 diagnostic test, and the appropriate actions are taken based on the test results;
- States should survey the hardest hit nursing homes prior to reopening to ensure the facility is adequately preventing the spread of COVID-19; and
- Nursing homes should remain in the current state of highest mitigation while the community is in Phase 1 of Opening Up America Again. Additionally, as States advance through the phases, nursing homes should lag behind the general community’s reopening by 14 days.
Visitation and Service Considerations – The nursing home phased reopening process also provides considerations for visitation and service through each phase. In Phases One and Two visitors are prohibited, except in compassionate care situations in Phase Two. Visitation is permitted in Phase 3 with screening and additional precautions, including social distancing. Generally, nursing homes should have no new cases of COVID-19 for 28 days prior to reopening for visitors. Additionally, the nursing homes should not be experiencing staffing shortages, PPE shortages, or testing shortages.
Restoration of Survey Activities – CMS recommends that States resume nursing home survey activities in Phase 2 and should use the following prioritization criteria when determining which facilities to survey first:
- For investigating complaints – Facilities with reports or allegations of abuse or neglect, infection control, violations of transfer requirements, insufficient staffing or competency, or other quality of care issues should be prioritized.
- For standard recertification surveys – Facilities that have had a significant number of COVID-19 cases, special focus facilities, special focus facility candidates, and facilities overdue for a standard survey should be prioritized.