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Policy Updates to Compliance Program Needed When Creating “COVID-19 Ready” Skilled Nursing Facilities and Units

Posted on May 18, 2020 in COVID-19 Daily Updates, Long-Term Care, Home Health & Hospice

Published by: Hall Render

States like Indiana, Connecticut and Maine are offering to pay nursing homes a higher per diem for COVID-19 presumptive residents or a higher percentage reimbursement rate if a nursing home qualifies as a “COVID-19 ready” facility, as discussed in our recent article here. As nursing homes assess, plan for and take actions to qualify as “COVID-19 ready” facilities, skilled nursing compliance professionals need to address the adjustments and additions to the nursing home’s compliance and ethics program.

State Requirements

Some state requirements for nursing homes to qualify as “COVID-19 ready” facility include:

  • Staff
    • The nursing home should have dedicated professionals and staff that work only in the COVID-19 area.
  • Equipment
    • The nursing home should have dedicated equipment used in the COVID-19 unit.
  • Space
    • The nursing home should have dedicated and separate space to care for residents with confirmed COVID-19, which could be a dedicated floor, unit or wing.
  • Hand Washing
    • The nursing home should have appropriate hand washing/sanitizing stations for all persons entering and exiting the COVID-19 Unit.

Plans, Policies and Procedures

Nursing homes need to review and update practices to address the specialized care and specific demands of a segregated unit, which include updating or creating the following policies and procedures.

  • Meals and Maintenance Services
    • The nursing home should have a specific plan for providing the COVID-19 unit with meals and environmental services.
  • New COVID-19 Infections
    • The nursing home should a written policy outlining the process for treating and handling nursing home residents who develop COVID-19. Will the resident be transferred to a single room?
  • Monitoring Procedure
    • The nursing home should establish a policy and procedure to closely monitor roommates and other residents who may be exposed to an individual with COVID‑19.
  • Admissions and Readmissions
    • The nursing home should create a plan for managing new admissions and readmissions of residents with and unknown COVID-19 status.

Next Actions

  • Nursing homes should assess if the higher payment opportunities are worth the additional building and operational requirements to qualify as a “COVID-19 ready” facility.
  • Nursing homes should review, revise and create policies and procedures for these dedicated teams and areas.

If you have questions or would like assistance with revising and creating the policies mentioned, please contact:

More information about Hall Render’s Post-Acute and Long-Term Care services can be found here.

Hall Render’s attorneys and professionals continue to maintain the most up-to-date information and resources at our COVID-19 Resource page, through our 24/7 COVID‑19 Hotline at (317) 429-3900 or by contacting your regular Hall Render attorney.

Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot—outside of an attorney-client relationship—answer specific questions that would be legal advice.