IDH & CMS Issues Holiday Guidance for LTCF Residents

Please Note:  On November 18, 2020, this article was updated to include CMS’s Holiday Guidance, which was issued on November 18^th.  CMS’s Holiday Guidance does not differ from IDH’s Holiday Guidance except that CMS recommends that residents be tested for COVID-19 if signs or symptoms are present upon returning from a holiday gathering or if a resident or their family reports possible exposure to COVID-19 while outside the facility.

On November 6, 2020, the Indiana Department of Health (IDH) issued Holiday Guidance for Residents of Long-Term Care Facilities and Residents’ Families and Representatives, which can be found in full here.  The Holiday Guidance applies to both comprehensive care facilities and residential care facilities (licensed assisted living communities).  Long-term care facilities are encouraged to share IDH’s Holiday Guidance with residents’ families and designated representatives and communicate your facility’s expectations / recommendations regarding holiday visits, as outlined further below.

Under the Holiday Guidance, IDH strongly recommends against families taking residents to their homes or to gatherings for holiday events, as the CDC has stated that small gatherings have been a significant driver of recent case increases.  However, IDH’s recommendation does not apply to residents who have been diagnosed with and recovered from COVID-19 in the last 90 days, if they meet the CDC’s criteria for the Discontinuation of Transmission-Based Precautions.  Instead of home visits and holiday gatherings outside of the long-term care facility, IDH recommends families and friends visit their loved ones in their long-term care facility, whether through outdoor visitation or indoor visitation, if permitted under IDH’s Visitation Guidelines at that time. Facilities are encouraged to begin planning now for increased visitation that may occur over the holidays.

For those families who will have a LTCF resident in their home over the holidays, IDH recommends the following:

• Decrease exposures for two weeks prior to your holiday gathering (i.e., avoid indoor settings with people you do not live with where you cannot socially distance or wear a mask).
• Wear a mask during any indoor holiday events and when travelling in the car with loved ones.
• Wash your hands and disinfect high touch surfaces regularly.
• Set up your house to allow for social distancing.
• Screen anyone entering your house for signs and symptoms of COVID-19.
• Make environmental changes to decrease the indoor spread of COVID-19, such as cracking windows and using HEPA filters or humidifiers.

For the CDC’s guidance on holiday gatherings, including additional mitigation strategies, please click here.

Recommendations for Residents Upon Return

Importantly, for those residents who do leave their long-term care facility for holiday events, the CDC currently recommends that they be placed in quarantine for 14 days upon return.  If a resident lives in a private residence or room, this means the resident would be separated from others in the facility for 14 days upon return.  If a resident has a roommate, the resident would be moved to an observation room upon return, if one is available, for 14 days.  If an observation room is not available, the resident may have to wait to return until such a room is available.  Under IDH’s Holiday Guidance, families and representatives are encouraged to discuss these scenarios with the facility’s administrator prior to a resident leaving for such holiday events.

CMS’s Holiday Guidance also recommends that residents be tested for COVID-19 if signs or symptoms are present upon returning from a holiday gathering or if a resident or their family reports possible exposure to COVID-19 while outside the facility.

Considerations for Long-Term Care Facilities

Based upon the recommendations for residents upon return, long-term care facilities should consider the following:

• Review your facility’s bed hold policy as soon as possible to determine if any changes are necessary.
• Determine the number of rooms that could be available for returning residents to complete their 14-day quarantine.
• Nursing facilities interested in making structural changes to accommodate additional observation rooms should review the following Waiver, and licensed assisted living communities interested in making structural changes to accommodate additional observation rooms should review the following Waiver.
• Provide a deadline to families and representatives to notify the facility if they are taking a loved one home, when, and for how long.
• Based on the amount of residents leaving for holiday gatherings, set clear expectations with families regarding whether a room may or may not be available upon the resident’s return.  If a room is not expected to be available, the facility should prepare a safe discharge notice and organize necessary treatments, medications, equipment, and any applicable instructions.  Discharge notices must be provided as soon as practicable (the applicable Waiver for nursing facilities can be found here, and the applicable Waiver for licensed assisted living communities can be found here here).
• Communicate with families when observation rooms become available.
• Plan for additional PPE being required with more residents being placed in observation upon return.