Current Requirements Other Resources Audience Q&A
What requirements are currently in place?
Current requirements come from two epidemic orders, MDHHS Epidemic Order October 4, 2022, “Requirements for Residential Care Facilities” and MDHHS Epidemic Order October 18, 2022, “Testing in SNF, HFA & AFC Facilities,” as explained below. In addition, there is return to work criteria for healthcare workers to follow, which is also explained below.
MDHHS Epidemic Order 10-4-22: Requirements for Residential Care Facilities- MDHHS Epidemic Order October 4, 2022 Requirements for Residential Care Facilities
- Revision of the May 21, 2021 Order
- Removes assisted living settings from the requirements to follow CMS QSO 20-39-NH guidance
- Utilize general CDC Guidance directed to AL settings
- Masking – based on facility Community Levels – use CDC COVID Data Tracker
- NOTE – different than Community Transmission Levels we have been using previously!!
- https://covid.cdc.gov/covid-data-tracker
- Use Community Levels data to determine needs
- Today, all MI Counties are either Green (Low) or Yellow (Medium)
- Core Principles:
- Stay up to date on vaccinations
- Distance when possible
- Hand hygiene
- Be aware of signs / symptoms or close contacts with a positive individual
- Positive Cases or Presumptive:
- Test – contact tracing or broad-based testing
- Isolate from others to prevent spread
- Use of Source Control (masks & PPE) for staff
- Treat mild symptoms / consider Paxlovid or other treatment
- MDHHS Epidemic Order October 18, 2022 Testing in SNF, HFA & AFC Facilities
- Revision of the October 12, 2021 Testing Order
- Aligns with CMS QSO-20-38-NH Revised
- Numerous links to CDC Guidance throughout
- Key Points:
- Vaccination status is unlinked from testing cadences
- Testing Cadence
- Symptomatic = test regardless of vaccination status immediately (Day 0, 2 & 4 if needed)
- Symptomatic residents placed in TBP/quarantine pending testing
- Outbreak =
- Initiate contact tracing & test only those affected Day 1, 3, & 5
- Broad based approach = test all Day 1, 3, & 5
- Routine testing = not recommended
- Must have a policy/procedure in place to address residents & staff who refuse testing.
- Healthcare Worker RTW Criteria
- CDC guidance at https://www.cdc.gov/coronavirus/2019-ncov/hcp/guidance-risk-assesment-hcp.html
- HCP who were asymptomatic throughout their infection and are not moderately to severely immunocompromised could return to work after the following criteria have been met:
- At least 7 days have passed since the date of their first positive viral test if a negative viral test* is obtained within 48 hours prior to returning to work (or 10 days if testing is not performed or if a positive test at day 5-7).
- HCP with mild to moderate illness who are not moderately to severely immunocompromised could return to work after the following criteria have been met:
- At least 7 days have passed since symptoms first appeared if a negative viral test* is obtained within 48 hours prior to returning to work (or 10 days if testing is not performed or if a positive test at day 5-7), and
- At least 24 hours have passed since last fever without the use of fever-reducing medications, and
- Symptoms (e.g., cough, shortness of breath) have improved.
Other Resources:
Audience Q&A from 11-03-22 Webinar:
Question: Would staff be off for the full 5 days?
Answer: If a staff member has a close contact, they may work using PPE & Source Control if they are asymptomatic. Test them on Days 1, 3, & 5 and if they test positive then remove them from the workplace. If they do not test positive during that time frame the additional precautions can be dropped.
Question: Can staff still work if they have no symptoms and use PPE with a negative test?
Answer: Staff may work post close contact using Source Control & with testing on Days 1, 3, & 5.
Question: Is testing required even if source control is used?
Answer: Yes, testing is required if you have a new positive test in either a resident or other staff member.
Question: When conducting contact tracing, how long before the positive test should we go back with our tracing?
Answer: Contact tracing should identify any contact within the prior 48 hours.
Question: If all staff are masked at all times, would we only test if there are symptoms?
Answer: Testing is required if 1) an individual demonstrates signs & symptoms, or 2) if you have a new positive test in either a resident or staff member.
Question: Won’t they still test positive at day 5? What do I do in that case if symptoms have improved?
Answer: It is possible that an individual will test positive on Day 5 even if symptoms are improving. If that is the case, continue testing (use an antigen test – not a PCR) every 3-5 days and follow the CDC criteria for return to work if it is a staff member. If it is a resident, maintain precautions (quarantine & source control).
Question: We’re still screening every employee, every day, at entrance and keeping those records – are we still required to do this or can we drop this?
Answer: You can drop this as indicated in the most recent changes to guidance in QSO-2039-NH.
Question: How about visitors coming in? Do we need to screen at the entrance and document?
Answer: You are not required to screen visitors either. If you choose to do this as part of your internal policy, you may do so, but it is not required.
Question: Is posting/notifications still a requirement?
Answer: Yes, notifications and postings are still required (sharing to residents, families and staff and posting in the building) within 12 hours.