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Bed Changes, Relocations, Use of Unlicensed Space - COVID-19 Facility Emergencies - IHCA

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Bed Changes, Relocations, Use of Unlicensed Space – COVID-19 Facility Emergencies

Posted Nov 9, 20203 min Read

Regulatory & Clinical
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Several IHCA members have reached out in the past couple of weeks to ask whether moving beds, using old resident rooms that had been converted to administrative use for resident care, or other reorganizational ideas can be performed to meet the demands of COVID-19.  With the increase COVID-19 across Indiana health care resources are being stretched very thin.  Available capacities in skilled nursing facilities are shrinking due to need for isolation rooms for Transmission Based Precautions and to provide surge capacity for hospital systems.

The answer for many of these questions is yes based on waivers issued by the Indiana Department of Health, with corollary authority in federal waivers, in the Spring of 2020.  The Fourth Emergency Order Granting Temporary Blanket Waivers for Comprehensive Care Facilities issued on March 21, 2020 permits the provision of care in alternative settings, including the movement of beds from one part of the facility to another, care in any bed regardless of certification type, care of residents in unlicensed settings, and remodeling/structural changes on an expedited basis.

To utilize any of these flexibilities a facility must:

  • Email Matt Foster (mfoster@isdh.in.gov), Brenda Buroker (bburoker@isdh.in.gov) and Miriam Buffington (mbuffington@isdh.in.gov) with the plans you desire to make based on the Fourth Emergency Order
  • The email must declare a “COVID-19 facility emergency” as this triggers use of the order
  • With respect to caring for residents in alternative settings, an uncertified bed, in an unlicensed area or in another part of a facility not the resident’s room, state that the facility:
    • Will render care and required services to a resident in the facility, but in a bed that is not certified for the reimbursement program the resident is enrolled in (i.e. rendering care for a Medicaid patient in a Medicare only bed); or
    • Will render care and required services to a resident relocated to an unlicensed space within the facility or in a different facility not licensed to provide skilled nursing care with the following information (1) immediate notice of the details of the relocation (resident name, new location, expected length of relocation); (2) that the relocation facility continues to meet all the resident’s care and safety needs; and (3) the facility notifies ISDH when the resident returns to their prior room or to a different room in the licensed space.
  • For emergency bed changes, ISDH is waiving certain application fees, notice and approvals for certain bed changes under 410 IAC 16.2-3.1-2(e) provided notice is given and a drawing and narrative of the bed change that has occurred or will occur is provided.  Temporary approval with retroactive effect is also offered in the waiver.  Some bed changes may be made permanent under certain circumstances but will also be reviewed in context of applicable law (permanent circumvention of the CON laws will not be permitted).
  • Remodeling and structural changes require meeting certain steps outlined in the Fourth Emergency Order, but application fees are waivers, notice and approval for remodels has been waived so long as certain advanced notice is given and drawings are provided within three days after completion.

There are a lot of options available to skilled nursing facilities to use available space for resident care during the pandemic, and particularly during surge capacity need.  Please contact Zach Cattell at zcattell@ihca.org with questions.