COVID-19 (Coronavirus)
Risk Management Recommendations

To find resources by clinical setting, click here

In general, all healthcare-related settings should:

Monitor daily phone calls and email briefings from your state and local health department. Then, begin your journey at The Centers for Disease Control and Prevention (CDC) Coronavirus Disease 2019 (COVID-19) webpage. The CDC offers strategies to prevent the spread of COVID-19 in multiple settings. This is your most important source for the latest guidelines, checklists, videos, strategies for responding to supply shortages, and more. Beware of imitation websites.

If you have not already done so:

Prepare to Care for COVID-19: Get your practice ready has practical tools for clinicians to use to care for patients.

All health facilities should take all steps possible to prepare for COVID-19 as outlined by the CDC at https://www.cdc.gov/coronavirus/2019-ncov/healthcare-facilities/steps-to-prepare.html

Conduct a self-assessment of infection control practices using the CDC tool appropriate to your setting. https://www.cdc.gov/hai/prevent/infection-control-assessment-tools.html

Communicate with staff regarding use of Personal Protective Equipment (PPE). This link provides comprehensive information related to PPE and its use for COVID-19. https://www.cdc.gov/coronavirus/2019-ncov/hcp/respirator-use-faq.html

CDC Emergency Operations Center: for emergency or urgent patient care assistance (not intended for us by general public)
24/7: 770-488-7100

HHS offers a resource exchange for healthcare emergency preparedness with sample tools, plans, best practices and more: https://asprtracie.hhs.gov/. Search the Technical Resources available for your topic. Specific tools are also grouped by setting.

The U.S. Department of Health and Human Services (HHS) provides a compendium of resources related to the COVID-19 situation at https://asprtracie.hhs.gov/technical-resources/44/coronaviruses-sars-mers-and-covid-19/27. Resources at this site assist in planning for infection-related emergencies of all types and remind users to also remain current with CDC directives.

Emergency Operations Plans, Tools and Templates https://asprtracie.hhs.gov/technical-resources/84/emncy-operations-plans-emncy-management-program/1#plans-tools-and-templates-eop

Also, go to the Public Health Emergency website of the US Department of Health & Human Services (www.phe.gov). At the very minimum, download and use the COVID-19 Healthcare Planning Checklist. This checklist identifies activities that various healthcare settings may undertake to prepare for, respond to, and be resilient in the face of COVID-19.

Key points for health care organizations have been compiled by The Joint Commission (TJC) and can be accessed at https://www.jointcommission.org/covid-19. This information is pertinent to ALL HEALTHCARE SETTINGS and is open access for all Joint Commission members AND non-members. Read and share as appropriate.

Refer to the U.S. Department of Labor Occupational Safety and Health Administration for infection prevention and control references, work environment, and training considerations related to COVID-19 at https://www.osha.gov/SLTC/covid-19/controlprevention.html#health as needed.

All health facilities should take all steps possible to prepare for COVID-19 as outlined by the World Health Organization: Coronavirus Information Page at https://www.who.int/emergencies/diseases/novel-coronavirus-2019

For a fact sheet on the regulatory flexibilities and other actions CMS is taking to help healthcare providers and states respond to and contain COVID-19, please visit: 
https://www.cms.gov/files/document/covid19-emergency-declaration-health-care-providers-fact-sheet.pdf

COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers 
https://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf

Review Disaster Plan/Emergency Management Plan, Infection Prevention and Control Plan, and Crisis Management Plan to ensure all aspects of response are leveraged.

Touch base with community partners. Be certain that call trees and emergency phone lists have current contact phone numbers for staff, physicians, and key stakeholders.

COVID-19 Resources by Clinical Setting

  • Navigating the Behavioral Health Impacts of the Coronavirus

https://www.thenationalcouncil.org/BH365/2020/03/03/navigating-the-behavioral-health-impacts-of-the-coronavirus/

National Council for Behavioral Health https://www.thenationalcouncil.org/covid19/             
Provides behavioral health concern management and links to CDC information

  • Mental Health and Coping During COVID-19

https://www.cdc.gov/coronavirus/2019-ncov/about/coping.html

Provides resources, including things you can do to support yourself, resources for parents, and responders (including people who have been released from quarantine).

  • Substance Abuse and Mental Health Services Administration

https://www.samhsa.gov/disaster-preparedness

Provides behavioral health resources, service locator related to behavioral health needs related to disasters including helpline:

1-800-662-HELP (4357) SAMHSA’s National Helpline is a free, confidential, 24/7, 365-day-a-year treatment referral and information service (in English and Spanish) for individuals and families facing mental and/or substance use disorders

Read and adhere to the April 2, 2020 guidelines:

Today, at the direction of President Trump, the Centers for Medicare & Medicaid Services (CMS), in consultation with the Centers for Disease Control and Prevention (CDC), issued critical recommendations to state and local governments, as well as nursing homes, to help mitigate the spread of the 2019 Novel Coronavirus (COVID-19) in nursing homes. The recommendations build on and strengthen recent guidance from CMS and CDC related to effective implementation of longstanding infection control procedures. Click here to continue reading the press release.

COVID-19 Long-Term Care Facility Guidance (PDF) (4/2/2020)


We recommend all senior or vulnerable population settings, including assisted living, independent living, group homes, personal care homes and residential living centers follow the Revised Guidance for Infection Control and Prevention of Coronavirus in nursing homes from CMS. This guidance prohibits most visitors and suspends communal dining and/or other communal activities. The CDC recommends all individuals maintain a 6-foot distance from other individuals. In semi-private rooms, we recommend you move all beds and chairs apart to maintain as much distance as possible between roommates.

Additional resources include:

Long-term care facility disaster references and templates https://www.cahfdisasterprep.com/eop

  • American Health Care Association and the National Center for Assisted Living

Updated March 2020

Sample Policy for Emergent Infectious Diseases for Skilled Nursing Care Centers 
http://www.cahf.org/Portals/29/DisasterPreparedness/pandemic/AHCA_NCAL_Infectious_Disease_Sample_Policy.pdf

  • Assisted Living: American Health Care Association and the National Center for Assisted Living

Taking Reasonable Efforts to Prevent COVID-19 From Entering Your Assisted Living Community (as of March 9, 2020)

Includes templates for letters to families, residents and employees and other resources.

https://www.ahcancal.org/facility_operations/disaster_planning/Documents/AL-Guidance-Preventing-COVID19.pdf  

General guidelines for high-risk groups

https://www.cdc.gov/coronavirus/2019-ncov/specific-groups/high-risk-complications.html

  • Long Term Care resources

https://www.cms.gov/medicareprovider-enrollment-and-certificationsurveycertificationgeninfopolicy-and/prioritization-survey-activities (3-23-2020)

https://www.argentum.org/coronavirustoolkit/

LeadingAge Texas https://www.leadingagetexas.org/general/custom.asp?page=CoronavirusResources

LeadingAge https://leadingage.org/coronavirus-resources

Want even more COVID-19 resources?

Emergency Operations Plans, Tools and Templates
https://asprtracie.hhs.gov/technical-resources/84/emncy-operations-plans-emncy-management-program/1#plans-tools-and-templates-eop

Refer to HHS Emergency Management and Incident Command System planning resources at 
https://www.phe.gov/Preparedness/planning/mscc/handbook/chapter1/Pages/emergencymanagement.aspx#1.3.1

Incident planning and resource guides with self-assessment checklist for infection Control incident
https://emsa.ca.gov/hospital-incident-command-system-incident-planning-guides-2014/

Infection Control Tools to implement standard and transmission-based infections for health care settings.
https://www.cdc.gov/infectioncontrol/tools/index.html

Infection Preventionist Job Description Template
https://apic.org/wp-content/uploads/2019/08/IP-Job-Description-web-version.pdf

CHECKLISTS:

California Hospital Seasonal Influenza Pandemic Preparedness Checklist (updated 2/2020; includes COVID-19 resources and links)
https://www.calhospitalprepare.org/sites/main/files/file-attachments/influenzapandemicchecklist.pdf

Interim Healthcare Coalition Checklist for Pandemic Planning National Healthcare Preparedness Programs (NHPP). Fall 2013. U.S. Dept. of Health and Human Services
https://www.phe.gov/Preparedness/planning/hpp/reports/Documents/pandemic-checklist.pdf

PLAN:

Pandemic Influenza Plan
https://www.cdc.gov/flu/pandemic-resources/pdf/pan-flu-report-2017v2.pdf

TRENDING

More than 140 nursing homes have reported coronavirus cases.

The virus is spreading, and it appears some of the cause of the spread in nursing homes is related to staff who travel between facilities. Consider staff and consultants who travel between facilities: Therapists, X-Ray Technicians, Delivery personnel (yes even mail delivery), clergy, and consultants. Also, many facilities have staff work at more than one facility on any given day. While tracking the reason for the spread of the Coronavirus is on everyone’s mind, Dallas, Texas has taken new stringent steps to curb the risk of personnel sharing facilities:

  • Immediate notifications after positive tests
  • No transfer of patients
  • All staff wear masks at all times
  • Part-time staff may work in only one facility.

Dallas is expected to issue more regulations on March 30th after four nursing homes, and the State School in Denton all recorded positive cases of the Coronavirus.

Being active “ahead of the game,” consider implementing the Dallas interventions and a few other restrictions such as:

  • Stop sharing PT, OT, and ST between facilities
  • Provide X-Ray services in ONLY 1 location in the facility, preferably near easy door access to limit the X-ray staff from walking through the facility
  • Provide lab draws in ONLY 1 location to limit access by lab personnel
  • Require staff to wipe down areas used by lab and X-ray after each use
  • Teleconference with all consultants. It is necessary to grant them remote access to EHR
  • Provide lawn chairs for visitors who want to visit through open windows (if you can’t open the window, provide cell phones for residents and wipe down the phone after each use)
  • Encourage FaceTime with families, stop in-person Care Plan meetings, opting for conference calls or FaceTime

Disclaimer

Risk management support provided by OmniSure Consulting Group, LLC is neither intended for nor should be construed as legal advice, and it is not intended to replace legal advice.

  • Information or documents provided are for illustrative purposes only and are not intended to dictate or replace company policy.
  • OmniSure is an independent risk management consulting firm, not an insurance company or an agent of an insurance company.
  • OmniSure’s contract review and risk management services are intended to provide best practice recommendations. These services are not intended, and should not be understood, to answer any policy-coverage questions or warrant compliance with any policy conditions or requirements. For terms and conditions, refer to the policy itself. Coverage is subject to exclusions. All questions regarding coverage or compliance with the terms, conditions, or provisions under a policyholder’s professional liability policy should be directed to the policyholder’s insurance agent or broker.
  • Discussing events with OmniSure does not constitute reporting an incident to your carrier and will not meet the reporting requirements of your policy.

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