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Updated CDC Guidance and What It Means for ACF and AL Providers

LeadingAge NY was surprised to learn that, despite the recent Centers for Disease Control and Prevention (CDC) COVID-19 updates and related updated nursing home guidance, the Department of Health (DOH) is not currently updating the COVID-19 guidance for adult care facilities (ACFs) and assisted living providers. LeadingAge NY believes that there are some questions given the updates in guidance and the existing State guidance and is advocating for the Department to look at these discrepancies.

Despite the lack of formal update, we do see some opportunity for providers to update some practices. The April 18th Health Advisory: Infection Prevention and Control Recommendations for Adult Care Facilities During the COVID-19 Pandemic does point some providers to the updated CDC guidance, and DOH has confirmed that providers noted in the passage should follow the updates. The passage is excerpted below:

ACFs licensed as an Assisted Living Residence (ALR), and/or certified as Enhanced Assisted Living Residence (EALR) or Special Needs Assisted Living Residence (SNALR) and Adult Homes or Enriched Housing Programs that offer services though an Assisted Living Program (ALP), or any ACF that is caring for one or more residents with SARS-CoV-2 infection, should adhere to applicable recommendations issued by the CDC in “Interim Infection Prevention and Control Recommendations for Healthcare Personnel During the Coronavirus Disease 2019 (COVID-19) Pandemic”.

Members should note that this guidance does not include ACFs that do not have a positive case and are not ALPs or ALRs.

On a positive note, the March 3rd Dear Administrator Letter (DAL) 22-26: Revised Visitation Guidelines points to CDC guidance in managing people who leave the facility for more than 24 hours. This has been updated to incorporate a test-based and source control strategy, rather than quarantining someone in their room. The guidance indicates that new admissions (including those who returned after being out of the facility for more than 24 hours) who are asymptomatic should wear source control for 10 days and be monitored for symptoms. In areas of high Community Transmission (which is currently most of the state), new admissions should be tested and, if negative, again 48 hours after the first test and, if negative, again 48 hours after the second test. Testing is not recommended for those who have recovered from COVID-19 in the prior 30 days. Transmission-based precautions may be considered under certain circumstances (e.g., resident cannot be tested or wear source control).

There is, however, discrepancy with State guidance dated May 31st entitled *NEW REVISED* Isolation & Quarantine Guidance regarding isolation and quarantine. Specifically, this guidance states that ACF residents and staff should adhere to the principles laid out in the directive regarding when quarantine or isolation is required. The criteria includes consideration to whether a person is up to date with their vaccination, which now includes the bivalent booster. It also indicates that the duration of any such quarantine or isolation should be 10 days. Both of those aspects are now inconsistent with CDC guidance and bear clarification.

Members should also note that the CDC recommends that facilities located in counties where Community Transmission is high may consider implementing broader use of N95s and eye protection by health care personnel (HCP) during patient care encounters. These recommendations are discussed more fully in the section entitled Implement Universal Use of Personal Protective Equipment for HCP on the above-linked CDC page.

Additional issues that we see as outstanding questions are passive versus active screening of visitors. We believe that the State recommendation on masking of staff and recommendation of residents wearing masks in common areas continue. Members are encouraged to send us any additional questions you may have.

We appreciate that this is extremely confusing. We are urging the State to update guidance to address outstanding questions and to ensure a proper balance between public health concern and resident quality of life.

Contact: Diane Darbyshire, ddarbyshire@leadingageny.org, 518-867-8828