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COVID Update April 1, 2020

Posted Apr 2, 20205 min Read

Regulatory & Clinical

ISDH Issues COVID-19 Guidance for Hospital Discharge to Long Term Care Facilities

Earlier this evening, the Indiana State Department of Health (ISDH) released COVID-19 guidance for hospital discharge to nursing facilities and skilled nursing facilities, and facilities sending of residents to the emergency department, which can be found in full here.

The guidance issued is substantially different from the original version provided to IHCA late last week.  IHCA worked with ISDH and the Indiana Hospital Association to ensure there was an understanding of the current resource limitations and staffing challenges across long-term facilities, as well as the danger of introducing COVID-positive patients and PUIs into COVID-naive facilities.

IHCA also worked to improve the issued guidance to ensure the prioritization of local collaboration between the long term care facility and discharging hospital, the patient’s medical needs and goals for care, the facility’s ability to carry out isolation precautions, and the patient’s clinical status and available test results.  Five patient categories were created to provide specific guidance to LTC facilities and hospitals.

The ISDH asks that this guidance be utilized when evaluating the transfer of a resident from the facility to the emergency department and of a patient from a hospital to a long term care facility.

If you have any questions regarding the guidance, please contact Zach Cattell (  or Lori Davenport (

Requirements of Participation Waivers/ISDH Licensure Waivers/ Requested CMS Waivers

IHCA recognizes the myriad of waivers that have been issued by the federal and state governments are confusing to keep track of.  The most recent waivers were issued by CMS and apply to the entire nation, called blanket waivers.  The new waivers, which we reported on March 30th, were added to blanket waivers previously issued by CMS last week.  The entire list of blanket waivers is here, and the LTC sections starts on page 9.

New CMS Waivers – Requirements of Participation

The new waivers addressed a variety of LTC Facilities Requirements of Participation and IHCA/INCAL has created a copy of the Requirements of Participation that clearly shows you the specific waived provisions with links between the provisions.  Click here to access.

The list of impacted Requirements of Participation are:

  • MDS submission timeframe
  • PBJ reporting
  • Physical Environment (for purposes of using currently non-certified buildings and areas of existing LTCs)
  • Resident Groups (for purposes of promoting social distancing)
  • Training and Certification of CNAs
  • Physician Visits
  • Resident Roommates and Groupings
  • Resident Transfer and Discharge (very specific requirements here)

These new waivers were added to previously issued CMS blanket waivers concerning the 3-day stay and PASRR completion timeframes.

In addition, these are added to the CMS waivers obtained by the Indiana Family and Social Services Administration regarding a variety of Medicaid enrollment and payment provisions.  You can read those on IHCA’s COVID-19 website.

ISDH Requests CMS Waivers – Requirements of Participation

In addition to the blanket waivers issued by CMS, ISDH Commissioner Kristina Box, M.D. submitted a request for more waivers of additional sections of the Requirements of Participation.  The ISDH request was submitted on March 30th.  Nearly all of the requests directly relate to state-level waivers that ISDH has issued in the past two weeks.

The list of requested waivers impact these Requirements of Participation:

  • Non-permanent employees (for purposes of the Indiana Personal Care Aide program)
  • Respect and dignity (to comply with visitation and gathering restrictions)
  • Requirements for training of paid feeding assistance (for purposes of the Indiana waiver on feeding assistant training)
  • Physician visits
  • Physical environment (for purposes of using currently non-certified buildings and areas of existing LTCs)
  • Resident Transfer and Discharge

The letter also included a request to waive many of the provisions that were included in the blanket waiver described above.

ISDH State-level Waivers and Orders

The ISDH has issued many state-level waivers and orders concerning comprehensive care licensure in the past two weeks and IHCA has reported on all of those. IHCA has created a chart of all of the ISDH state-level waivers for your reference.  Click here to access.

CMS Call with Nursing Homes Today at 4:30 EDT

Please join the Centers for Medicare and Medicaid Services (CMS) on Wednesday, April 1st at 4:30 PM EDT for a COVID-19 Call with Nursing Homes. CMS leadership will provide updates on the agency’s latest guidance. There will be audience Q&A and an opportunity for you to share best practices with your peers. The call will be recorded if you are unable to join. Conference lines are limited, so you are highly encourage you to join via audio webcast, either on your computer or smartphone web browser.

Participant Dial-In: (877) 251-0301

Conference ID: 8395995

Audio Webcast