State Rescinds 2021 ADHC Reopening Guidance
The Department of Health (DOH) issued guidance last week for adult day health care (ADHC) programs providing a revised process for reopening of programs that are still closed following COVID-19-ordered closures. The guidance also rescinds many of the COVID-19 restrictions that were hampering ADHC operation and admissions.
The new guidance document is available here; note the old guidance here for comparison purposes. Programs should note that the new guidance rescinds the March 2021 reopening guidance. The Adult Day Health Care Council (ADHCC) has reached out to request a correction, as the guidance should be rescinding the July 2021 guidance.
Programs should note that DOH requires programs to follow general infection control guidance from the Centers for Disease Control and Prevention (CDC) as noted here, including the bulleted infection control provisions below:
Effective with the date of this letter, ADHC programs planning to reopen must follow the Centers for Disease Control (CDC) Core Infection Prevention and Control Practices for all staff and registrants found at this link: https://www.cdc.gov/infectioncontrol/guidelines/corepractices/index.html
ADHC programs must have infection control policies and procedures established and in place prior to reopening. Additional reopening infection control policies that address and ensure:
- Registrant, staff and visitor screening upon arrival to the program in accordance with Department of Health (“Department”), Centers for Medicare and Medicaid Services (CMS), and CDC guidelines;
- Staff follow Department and CMS guidance on proper use of personal protective equipment when caring for registrants;
- All registrants are free from communicable disease upon return to program; and
- All staff wear a mask during operating hours, in accordance with current State and CDC guidelines.
Programs should note that they may provide passive screening of registrants and staff, as currently carried out in nursing homes for staff and visitors. Signage in program should be posted regarding the symptoms of COVID-19 and the need for testing and isolation if necessary.
Like all health care providers, ADHCs should develop their own masking policies and procedures for staff and registrants by reviewing local metrics regarding infection and awareness of infections and potential outbreak status in program. Programs should refer to CDC recommendations for developing these policies. Programs are no longer required to test registrants before admission, only refer to the registrant's primary care practitioner’s history and physical and its determination regarding a registrant being free from communicable disease.
Note the following July 2021 provisions not included in the new guidance:
- To open, each plan submitted by the ADHC program should contain policies and procedures that ensure:
- If only fully vaccinated registrants and fully vaccinated staff are engaged in group activities or meals, such persons may engage in the group activity or meal without the use of a face mask or face covering and without 6 ft. social distancing;
- If any unvaccinated (including those not fully vaccinated) registrant, staff, or visitor is present during group activities or meals, all individuals must wear a face mask or face covering, as medically tolerated, and maintain 6 ft. social distancing requirements, unless a physical distance of less than 6 ft. is required for safety or core function activity (i.e., assisting with eating or toileting);
- ADHC registrants not engage in communal dining with nursing home residents until further notice;
- ADHC registrants do not engage in activities with nursing home residents until further notice; and
- Unvaccinated registrants wear a face mask or face covering as medically tolerated and maintain 6 ft. of social distance (unless a physical distance of less than 6 ft. is required for safety or core function activity).
If plans have not been admitting unvaccinated registrants, they may move ahead and do so at this time. Social distancing and masking are no longer required when unvaccinated individuals are in program.
The 2021 provisions on infection control and transportation are also not provided for in the new guidance. However, programs should review the general CDC infection control guidance referenced above. Several provisions in the infection control section are best practices and should be retained.
Programs should note that they are required to offer vaccinations to both registrants and staff. If declined, the programs should record declination. Vaccinations are not mandatory for staff or registrants.
While provisions related to commingling of registrants with nursing home residents are not provided for in the new guidance, the Department has communicated that this restriction still exists. The Home and Community-Based Services (HCBS) Settings Rule prohibits routine events, activities, meals, and other commingling between the two populations. If programs have registrants who would like to attend special or public events associated with the nursing home, those activities should be noted in the registrant’s care plan.
The guidance also addresses the process for reopening of a closed ADHC program. While the guidance refers to full compliance prior to opening, DOH has allowed a staged reopening for programs requiring initial information to be provided with follow-up after reopening. The Department has communicated its commitment to expediting reopenings within a two-week time frame.
Members should contact Meg Everett if they have questions.
Contact: Meg Everett, firstname.lastname@example.org, 518-867-8871