Alabama COVID-19 Office Hours FAQ

The CMS memo “Guidance for the Expiration of the COVID-19 PHE” released on 5/1/23 states that CMS will not expect providers to meet the requirements at 42 CFR 483.80(g)(3) at this time. 483.80(g)(3) references reporting COVID-19 information to residents, their representatives, and families.

According to CDC guidance, facilities should post visual signage at entrances and common areas so that everyone in the building is aware of the IPC practices in the facility. You do not necessarily have to visually post verbiage that the facility is in outbreak, as long as you provide information on what IPC practices should be conducted while in the facility (e.g., source control, hand hygiene, visitation in resident rooms when facility is conducting an outbreak investigation, etc.). Your signage can change depending on the COVID-19 status at the facility.

So, if there are no cases in your facility, you can keep general signage about source control. When transmission levels are medium and high, signage should include additional information to ensure individuals are aware to report and/or limit entry if the following are met: positive viral test, symptoms of COVID-19, or close contact with someone with SARS-CoV-2.

If the facility is conducting an outbreak investigation, signage may change. For example, the type of source control that is recommended when in outbreak. If that looks different than what HCP and residents wear when hospital admission levels are medium or high, then this may be something that changes for your visual alerts. Another example of signage that may be posted during an outbreak would be the recommendation for visitation to occur in resident rooms. It will be dependent on what your facility policy says and again may change based on what is going on within the facility and/or community.

You can use the CDC’s “Know Your COVID-19 Hospital Admission Level”. Per the website, data is updated every Thursday.

Our recommendation is to base facility level IPC practices on the facility’s county hospital transmission rates.

While admission screening is at the discretion of the facility, looking at other counties where admissions are coming from could help inform individual level IPC practices such as screening and source control. This is not a requirement and will depend on what practices the facility has decided to adopt for admissions.

Per CDC guidance, facilities should test close contacts or unit/facility wide on days 1, 3, and 5 and may discontinue screening if the first three rounds of test results come back negative.

The return to work guidance provided yesterday was the time frame for when facilities are operating at a conventional capacity. If your facility is implementing contingency or crisis staffing strategies, your return to work policy will need to define the criteria for when the facility will move from conventional staffing to contingency or crisis staffing. You would then follow the return to work time frames for those two categories.

CMS interim final rule issued on Nov. 5, 2021 regarding staff COVID-19 vaccination requirements will soon end which required all healthcare staff to be fully vaccinated for COVID-19. Although CMS has not provided any additional information on COVID-19 vaccination requirements for employees at this time, they continue to urge everyone to stay up to date on their vaccinations.

According to the updated CDC guidance, facilities should consider implementing broader use of respirators and eye protection by HCP during patient care encounters when the COVID-19 hospital admission levels are high. Facilities will need to decide how they will adopt prevention measures when levels are increasing. It is not a requirement per CDC, however CMS expects that facilities are following CDC guidance.

Facilities should implement universal use of respirators and eye protection during all patient care encounters when COVID-19 transmission metrics are high, however it is not recommended to wear full COVID-19 PPE (gown, gloves, N95 respirator, and eye protection) for AGPs unless the person is suspected or confirmed to have COVID-19.

Due to no current N95 mask shortages, facilities should promptly resume conventional practices for the use of N95s, meaning they should be discarded after each encounter.  All FDA-cleared N95 respirators are labeled as single use disposable devices.

If you have staff that cannot wear N95s for source control, it would be reasonable to have them wear a well-fitted mask. According to CDC guidance with broader use of source control, a well-fitting face mask or N95 respirator is acceptable. Your IPC policy should define when a well-fitting facemask or N95 respirator is to be worn based on COVID-19 transmission metrics and healthcare provider’s personal preference.

Facilities should follow CDC’s return to work time frames under the Interim Guidance for Managing Healthcare Personnel with SARS-CoV-2 Infection or Exposure to SARS-CoV-2.

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.

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 severe to critical illness who are not moderately to severely immunocompromised could return to work after the following criteria have been met:

• At least 10 days and up to 20 days have passed since symptoms first appeared, 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.
• The test-based strategy as described below for moderately to severely immunocompromised HCP can be used to inform the duration of work restriction.

Facilities may consider using CDC’s Strategies to Mitigate Healthcare Personnel Staffing Shortages to address staffing shortages using contingency or crisis strategies. Facilities should have well defined criteria for when they would adopt a strategy other than the conventional approach. Facilities implementing staffing shortage criteria would follow the return to work time frames for each respective category.

Based on the revised CDC guidance dated May 8, 2023, the recommendation for daily symptom checks is no longer required.

Based on the revised CDC guidance dated May 8, 2023, the facility is recommended to establish a process to ensure everyone is aware of recommended IPC practices in the facility and establish a process to make everyone entering the facility aware of recommended actions to prevent transmission to others.

Since the regulation that speaks to the “additional precautions” for unvaccinated staff has ended, the facility should follow CDC guidance on implementation of source control for everyone in the facility regardless of vaccination status.