LeadingAge NY Urges DOH to Rightsize and Fund PPE Stockpile Requirements
LeadingAge NY called for rightsizing of government and nursing home personal protective equipment (PPE) stockpiles and an adjustment in nursing home Medicaid rates to account for stockpile costs in comments requested by the Department of Health (DOH) on its nursing home stockpile requirements. DOH requested input into its methodology for calculating the required quantities of PPE under the nursing home stockpile regulations after LeadingAge NY submitted several rounds of comments in response to emergency regulations, criticizing the existing methodology. The association pointed out that the existing methodology results in the purchase of excessive amounts of PPE that in some cases cannot be used before its expiration date, wasting precious resources.
At the November meeting of the Public Health and Health Planning Council, consideration of the permanent adoption of the PPE stockpile methodology was deferred in order to allow DOH to reconsider its methodology. The regulation was ultimately renewed on an emergency basis for 60 days, which will expire in January.
In response to the Department's solicitation of input, LeadingAge NY recommended the following:
- DOH's Office of Primary Care and Health Systems Management, Office of Aging and Long Term Care, and Office of Health Emergency Preparedness should work together with stakeholders to ensure that government stockpiles are appropriately sized and that distribution policies are based on agreed-upon principles, such as regional incidence or prevalence, vulnerability of populations served, and services provided.
- Nursing home Medicaid rates should be adjusted to take into account the cost of stockpiles.
- Determine the quantity of required PPE based on projected occupancy, rather than certified beds.
- Assume that N95 masks will substitute for face masks in certain contexts.
- Implement a methodology that takes into account the shelf life of PPE.
- Implement a methodology that accounts for reusable PPE (the current methodology does not).
LeadingAge NY will keep members informed about the development of new regulations as the process progresses.
Contact: Karen Lipson, klipson@leadingageny.org