Maine Health Care Association



In order to reduce the risk to our residents, families and staff at __________________we have developed the following COVID-19 testing plan based on identified risks within our facility, the community at large and our state’s reopening plan.In order to begin a phased reopening plan our facility must take steps to reduce the potential of exposure by developing a plan for routine staff testing at ____________________. This document contains the approach that ______________________ will take for testing staff and residents. Our facility will follow guidance from the State of Maine Center for Disease Control and Prevention regarding testing strategies for both residents and staff (who should be tested, at what frequency, resulting actions, etc.). It will be extremely important that providers document the guidance from DHHS/DLC/MECDC and their efforts to obtain testing and meet that guidance. In absence of state guidance, providers should consider federal CDC guidance on testing for COVID-19 in nursing homes.CDC Testing Guidance for Nursing Homes can we found here: This guidance addresses who should be tested, when to test and at what frequency. It also aligns with the recent CMS memo QSO-20-38 with recommendations for state and local officials on reopening nursing homes. STAFF MEMBERS/EMPLOYEE TESTING: This facility’s plan/process for conducting baseline testing of all staff (including volunteers, vendors, student nurses and nurse aides) and for conducting retesting will be consistent with Maine CDC staff retesting recommendations and the federal requirements for testing based on county positivity rates identified in CMS memo QSO-20-38.We will test all staff based on the extent of the virus in the community, using CMS’ published county positivity rate in the prior week as the trigger for staff testing frequency. We will monitor our county positivity rate every other week (e.g., first and third Monday of every month) and adjust the frequency accordingly. If the county positivity rate decreases to a lower level of activity, our facility will continue testing staff at the higher frequency level until the county positivity rate has remained at the lower activity level for at least two weeks before reducing testing frequency.If a county positivity increases to a higher level of activity, our facility will immediately adjust to that testing frequency. Currently, as a facility located in a county with a positivity rate of ____________ during __________time period we shall retest all staff following the initial baseline testing at least:Every 30 days based on a positivity rate below 5%Every week based on a positivity rate between 5% and 10%*Twice weekly based on a positivity rate above 10%**In order to meet the required frequency of testing ______________ will consider the use of available Point of Care testing on-site for asymptomatic individuals when off-site testing availability is limited or turnaround time is <48 hours.As a facility located in a county designated by the Maine CDC as an area of community transmission (York, Cumberland, Androscoggin) we shall retest all staff following the initial baseline testing at least every two weeks from the last sample collection date for each individual staff person.ORAs a facility in a county designated by the Maine CDC as an area of low-to-no community transmission we shall retest all staff at least 30 days from the date of the last sample collection date.IN ADDITIONContract Staffing Agencies will be required to show proof of testing consistent with the retesting recommendations for our specific facility as outlined in the updated contract. (Facilities using agency staff should review whether they will be responsible for the testing of these individuals or if they will amend current contracts to require proof of testing from the agency directly). Volunteers, vendors, student nurses and nurse aides will be tested in compliance with the current facility retesting plan. If an individual is new to the facility or has not been tested within the last 14 days, the facility will ensure that a test is performed prior to entering the building and will continue as the facility policy requires.Please Note: This guidance is subject to change as the COVID situation evolves. To ensure that the facility plan follows and is appropriately updated the facility infection preventionist or designee will check the Maine CDC website daily. RESIDENT TESTING:The plan/process for conducting testing of residents will follow Maine CDC and DHHS guidance not recommending baseline testing of all residents, our facility will continue to test residents based on their physician’s order, or in concert with the Maine Center for Disease Control and Prevention (CDC) as the result of a COVID-positive staff or resident in the facility.Following the CDC recommendations, this facility will take the temperature of all residents and ask them if they have any COVID-19 symptoms daily. In addition, we will perform viral testing of any resident who has signs or symptoms of COVID-19. Clinicians will use their judgment to determine if a resident has signs or symptoms consistent with COVID-19 and whether the resident should be tested. Our facility will perform expanded viral testing of all residents in the facility if there is an outbreak in the facility (i.e., a new SARS-CoV-2 infection in any HCP or any nursing home-onset SARS-CoV-2 infection in a resident). According to the CDC, when one case is detected in a nursing home, there are often other residents and HCP who are infected with SARS-CoV-2 who can continue to spread the infection, even if they are asymptomatic (). Except for severely immunocompromised residents, this facility will use the symptom-based strategy to determine when to discontinue Transmission-Based Precautions for residents. Resident with mild to moderate illness who are not severely immunocompromised:At least 10 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 improvedDepending on the prevalence of COVID-19 in our community, new admissions or residents returning from extended stays outside the facility will be placed in a single-person room or in a separate observation area so the resident can be monitored for evidence of COVID-19. Staff members who have close contact with this resident will wear an N95 or higher-level respirator (or facemask if a respirator is not available), eye protection (i.e., goggles or a face shield that covers the front and sides of the face), gloves, and gown when caring for these residents. Residents will be transferred out of the observation area to the main facility if they remain afebrile and without symptoms for 14 days after their admission or return from the extended stays outside the facility. Testing at the end of this period may be considered to increase certainty that the resident is not infected depending on availability of testing.STAFF TESTING PROTOCOLPublic and private testing capacity has expanded in Maine in recent weeks, giving nursing facilities options to consider as they develop staff testing protocols. Our facility testing protocol will be as follows (PLEASE NOTE: DHHS is not recommending baseline testing of all residents. Residents should continue to be tested based on their physician’s order, or in concert with the Maine Center for Disease Control and Prevention (CDC) as the result of a COVID-positive staff or resident in the facility).Our facility will have clinical staff swab other staff members, or have clinical staff supervise staff who self-swab. Once the specimen is collected the swabs will be tested at the State’s Health and Environmental Testing Lab (HETL) in Augusta. Under this model, our facility will request swabs and viral transport media through our County’s Emergency Management Agency. We will coordinate the timing of such testing with HETL to avoid unnecessary delays in processing of samples. Our facility clinical staff or a contractor will collect samples from staff, and have the samples tested in a private lab; orWe will arrange for staff to be tested on a schedule coordinated with DHHS through one of the many Swab and Send sites recently announced by Governor Mills found at: – Northern LightBrewer – PCHCOld Town – PCHCAugusta – MaineGeneralPortland – Northern LightSouth Portland – Northern LightBelfast – PCHCEllsworth – Northern LightBlue Hill – Northern LightDover-Foxcroft – Northern LightPresque Isle – Northern LightCalais – Calais Regional HospitalGreenville – Northern LightWaterville – Northern LightPittsfield – Northern LightBar Harbor – MDI HospitalFort Kent – Northern Maine Medical CenterMobile site – Promerica HealthThe City of WestbrookSkowhegan – Redington-Fairview General HospitalLincoln – Penobscot Valley HospitalSanford – York County Community Action Corp./Nasson Health CareBack Up Laboratory Plan for Testing ProtocolIn the event that our facility is unable to complete our routine staff testing through the planned lab provider we will utilize the following back up lab to complete the testing protocol: ___________________________________________. (Below is not an all-inclusive list of lab providers but some potential partners that MHCA is aware of).Maine Based Laboratory Providers:Nordx, 800-773-5814Midcoast/Parkview Laboratories, 207-373-6550CMMS Outpatient Labs, 207-795-5780Northern Light Laboratories, 207-973-6900Maine General Medical-Thayer Campus, 207-872-1000Quest Diagnostics, 207-406-3146PCHC Laboratories, 207-404-8000Out of State Laboratory Providers:Interpath labs, 800-452-8106Apex Laboratories, 800-976-6691ARUP Laboratories, Inc., 800-522-2787Laboratory Corporation of America, 800-343-8974Abbott Laboratories, Inc. 224-667-6100In this event, we will get testing supplies through___________________ and coordinate with the back up lab provider to arrange for transport and completion of test results. We will identify through our contract process the specific protocol for ensuring staff testing is completed in the event our primary lab is unavailable.In the event that lab services or testing supplies become unavailable or are in short supply making this facility unable to perform routine staff testing in compliance with our current staff testing strategy we will notify the DLC of our inability to perform testing through @ or directly via email/voice call to Maine CDC/DHHS for guidance. PUBLICLY POSTING RESULTSAfter verification with DLC, which Phase of the CMS QSO-20-30-NH our facility is in and with each round of staff testing (based on the frequency outlined in this policy we will publicly post our phase status and the most recent testing results in the following way: Through the facilities already existing COVID communication strategy via email and social media.By publicly posting this information in the lobby of the building with the exception of specific testing numbers. We will provide this information upon request.Through weekly social media resident and family updates.Through administrative emails to families and directly to residents.Other: In addition to publicly reporting testing results, if our facility conducts any testing using the in house POC testing devices under a CLIA certificate of waiver our facility will comply with the requirement for laboratories to report data for all individual tests completed following State of Maine DHHS and CDC guidance on reporting of such procedures.Infection Prevention During TestingFor providers collecting specimens or within 6 feet of resident/staff person suspected to be infected with SARS-CoV-2, our staff will maintain proper infection control and use recommended personal protective equipment (PPE), which includes an N95 or higher-level respirator (or facemask if a respirator is not available), eye protection, gloves, and a gown, when collecting specimens.For providers who are handling specimens, but are not directly involved in collection (e.g. self-collection) and not working within 6 feet of the resident or staff person, follow Standard Precautions. Healthcare personnel will continue to wear a form of source control (facemask or cloth face covering) at all times while in the healthcare facility per CDC guidance.Handling Bulk Packaged Sterile Swabs and Testing ProcedureSterile swabs for upper respiratory specimen collection may be packaged in one of two ways:Individually wrapped (preferred when possible)Bulk packagedBulk-packaged swabs may be used for sample collection; however, care must be exercised to avoid SARS-CoV-2 contamination of any of the swabs in the bulk-packaged container.Procedure for Supervising of Self SwabBefore engaging with staff or resident and while wearing a clean set of protective gloves, distribute individual swabs from the bulk container into individual disposable plastic bags.If bulk-packaged swabs cannot be individually packaged:Use only fresh, clean gloves to retrieve a single new swab from the bulk container.Close the bulk swab container after each swab removal and leave it closed when not in use to avoid inadvertent contamination.Store opened packages in a closed, airtight container to minimize contamination.Keep all used swabs away from the bulk swab container to avoid contamination.As with all swabs, only grasp the swab by the distal end of the handle, using gloved hands only.When staff members are self-collecting their swabs under clinical supervision:Hand a swab to the staff member only while wearing a clean set of protective gloves.The staff member can then self-swab and place the swab in transport media or sterile transport device and seal.If the staff member needs assistance, you can help the staff member place the swab into transport media or a transport device and seal it.What to do When Staff Test PositivePer CDC Return to Work Criteria guidance, our facility has taken steps to prepare for potentialstaffing shortages and have plans and processes in place to mitigate them. This information can be found in our crisis staffing plans.Limits of Testing and Caution on Assumptions from ResultsTest results capture the presence or absence of the virus at the time the specimen wascollected. The person’s condition may change with subsequent exposure, and per CDCguidance, testing must be implemented in addition to recommended IPC measures.Considering test results are not 100% accurate, nor do test results always identify when aperson is infected due to the incubation period, our facility will considering everyinteraction as a risk of potential transmission. For that reason we will ensure that residents and any essential personnel and visitors are wearing source control masks during this period of phased reopening.Reimbursement for Testing Residents and StaffMedicare fee for service and Medicare Advantage plans will cover the cost of COVID-19diagnostic (PCR) tests. Tests range in cost from $115 to $500. Medicare Part B will onlyreimburse approximately $100 for the PCR and $35 for other tests.Not all labs will bill Medicare directly. Our facility, wherever possible, will work with labs that will bill Medicare. If a lab does not have the ability to bill Medicare, the facility will pay for the tests upfront and seek reimbursement through Medicare Part B for the cost of the test. CMS has confirmed that health care providers and laboratories may bill Medicare and other health insurers for COVID-19 tests performed on or after February 4.Resident RefusalsA resident who has signs or symptoms of COVID-19 and refuses testing are placed on TBPuntil the criteria for discontinuing TBP have been met. If outbreak testing has been triggered and an asymptomatic resident refuses testing, our facility will continue to be extremely vigilant, such as through additional monitoring, to ensure the resident maintains appropriate distance from other residents, wears a face covering, and practices effective hand hygiene until the procedures for outbreak testing have been completed.If a resident refuses to be tested and follow infection prevention practices (e.g. stay in their room, use source control masks, etc.) then this facility may confer with Maine Division of Licensing and Maine LTC Ombudsman prior to taking any additional action. If a resident cannot be tested voluntarily (e.g., a resident with dementia who would have to be forcibly held by staff in order to be tested), forcible administration (e.g. use of restraints) of COVID-19 testing would violate regulations. Employee RefusalsAs an LTC provider we will be requiring COVID-19 testing as a condition of employment. This includes terminating or not hiring a person who refuses a COVID-19 test. As a facility and following the Maine state guidance on staff testing we have amended our employment contracts to include this condition of employment in order to follow state requirements for making such a policy, which may include modifying employment contracts that already exist where applicable.As a facility we will ensure that staff who have signs or symptoms of COVID-19 and refuse testing are prohibited from entering the building until the return to work criteria are met. If outbreak testing has been triggered and a staff member refuses testing, the staff member will be restricted from the building until the procedures for outbreak testing have been completed. This facility will follow its occupational health and local jurisdiction policies with respect to any asymptomatic staff who refuse routine testing.Documentation of Testing ResultsOur facility will ensure appropriate documentation to demonstrate compliance with the federal testing requirement as follows:For symptomatic testing of residents and staff:Document the date(s) and time(s) of the identification of signs or symptoms, when testing was conducted, when results were obtained, and the actions the facility took based on the results.For outbreak testing:Document the date the case was identified, the date that all other residents and staff are tested, the dates that staff and residents who tested negative are retested, and the results of all tests.For staff routine testing:Document the facility’s county positivity rate, the corresponding testing frequency indicated (e.g., every other week), and the date each positivity rate was collected. Also, document the date(s) that testing was performed for all staff, and the results of each test.Document the facilities procedures for addressing residents and staff that refuse testing or are unable to be tested and document any staff or residents who refused or were unable to be tested and how the facility will address those cases.When necessary, such as in emergencies due to testing supply shortages, documentation will include theDate, time and person with whom the facility contacted at Maine DHHS DLC and CDC to assist in testing efforts, such as obtaining testing supplies or processing test results.For facility staff tested elsewhere, documentation will be obtained showing that testing wascompleted under the same time frame as the current facility testing schedule within 24-48 hours of the scheduled testing routine. ................
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