DOH Issues Q&As on New Nursing Home Visitation Guidance
The Department of Health (DOH) has issued a 'questions and answers' (Q&A) document to clarify certain aspects of its Feb. 23rd nursing home visitation guidance. While many questions remain unanswered, the document sheds light on the following key issues:
- 14-Day COVID-Free Requirement: For purposes of determining whether a facility has been COVID-free for 14 days, "'new onset' is defined as a facility-onset COVID-19 case, i.e., a case that originated in the nursing home, as defined in CMS QSO 20-30, and includes both staff and residents." (See below for more information.)
- Compassionate Care Visits:
- End-of-life or compassionate care visitors are counted toward the visitor cap of 20 percent of the resident census at any one time. However, this percentage does not include members of the Long Term Care Ombudsman Program. These two points are important to note, as the visitation guidance document suggests a different interpretation.
- While compassionate care situations may extend past end-of-life situations, DOH still believes that these visits "should not be routine, and [should be] allowed on a limited basis as an exception to restricting visitation."
- Rapid Tests:
- Facilities that conduct rapid tests must report the results through the Electronic Clinical Laboratory Reporting System (ECLRS). Although not specified in the Q&A document, LeadingAge NY has been informed by the DOH ECLRS team that if a nursing home reports its results through the National Healthcare Safety Network (NHSN) and confirms that ECLRS is receiving those results, it need not report through ECLRS.
- Visitors who test positive must be reported to the local health department.
- Nursing homes that conduct rapid tests should have policies that identify who is responsible for performing specimen collection from visitors and a process for specimen collection.
Notably, the 14-day COVID-free requirement relies on CMS QSO-20-30-NH, which defines “new, nursing home onset” as:
COVID-19 cases that originated in the nursing home, and not cases where the nursing home admitted individuals from a hospital with a known COVID-19 positive status, or unknown COVID-19 status but became COVID-19 positive within 14 days after admission. In other words, if the number of COVID-19 cases increases because a facility is admitting residents from the hospital AND they are practicing effective Transmission-Based Precautions to prevent the transmission of COVID-19 to other residents, that facility may still advance through the phases of reopening. However, if a resident contracts COVID-19 within the nursing home without a prior hospitalization within the last 14 days, this facility should go back to the highest level of mitigation, and start the phases over.
While this does not entirely clear up questions on this issue, it does indicate that a resident in the first 14 days from admission from a hospital who tests positive does not trigger suspension of visitation, if the facility is practicing transmission-based precautions (TBP). By analogy, residents who test positive within 14 days from admission from the community do not trigger suspension of visitation, if the facility is practicing TBP. We recognize that there are many other situations in which a resident or staff person tests positive that are not addressed by the Q&A or by this definition.
We will continue to seek answers to your questions from DOH. Nursing homes are also encouraged to submit their questions to the DOH COVID-19 nursing home mailbox.
Contact: Karen Lipson, klipson@leadingageny.org, 518-867-8838