March 18, 2020

CMS Issues COVID-19 Guidance to Home Health Agencies

The Centers for Medicare & Medicaid Services (CMS) released Quality, Safety & Oversight Group guidance for infection control and prevention concerning coronavirus disease 2019 (COVID-19) for all Medicare and Medicaid participating home health agencies (HHAs) on March 10, 2020. This guidance is intended to reinforce recommendations set forth by the Centers for Disease Control and Prevention (CDC), with specific considerations for treating patients at home and limiting the transmission of COVID-19 in home care settings.

The guidance focuses on:

  1. Screening patients for COVID-19
  2. Monitoring and treating patients with confirmed COVID-19 at home
  3. HHA personnel screening for COVID-19
  4. Transferring a patient with COVID-19 to a hospital
  5. Addressing supply shortages

HHAs Screening Patients for COVID-19

CMS recommends that HHAs identify patients at risk for having COVID-19 infection before or immediately upon arrival to the home by asking: (1) whether the patient has traveled internationally within the last 14 days to countries with sustained community transmission (updated list), (2) whether the patient has experienced signs or symptoms of a respiratory infection, (3) whether the patient has been in contact with someone, within the last 14 days, with or under investigation for COVID-19, and (4) whether the patient is residing in a community where community-based spread of COVID-19 is occurring. HHAs must inform the HHA clinical manager, and local and state public health authorities of any person under investigation for COVID-19. It is important for HHAs to identify patients at risk prior to entering the home so health care personnel ensure they are following the proper protocol to avoid transmitting or contracting the virus. HHAs should advise the patient to adhere to self-isolation measures and advise family members on actions to prevent the spread of COVID-19 in the home.

Monitoring and Treating Patients With Confirmed COVID-19 at Home

When treating patients at home with known or suspected COVID-19, HHAs should seek to ensure that: (1) all health care provider (HCP) personnel wear recommended personal protective equipment (PPE), including gowns and surgical masks, (2) the number of HCP should be limited to essential personnel only, and (3) supplies brought into, used and removed from the home must be cleaned and disinfected in accordance with environmental infection control guidelines. HCPs should put PPE on outside of the home prior to entry or, at a minimum, face protection prior to entry, and should discard used PPE outside the home before departing the home health service location. HCPs are encouraged to perform appropriate hand hygiene prior to removing face protection and disposing of PPE and immediately after disposing of the used PPE. In making a decision to stop these transmission-based precautions when treating home care patients, HHAs should consider the disease severity, illness signs and symptoms, and a set of negative results of laboratory testing for COVID-19.

HHA Personnel Screening for COVID-19

HHAs should direct all personnel who have COVID-19 symptoms to not report to work. If COVID-19 signs and symptoms arise while on the job, HHAs should direct the employee to immediately stop work, put on a facemask, self-isolate at home and inform the HHA manager of all pertinent information. CMS also urges HHAs to refer to the CDC’s guidance for exposures that might warrant restricting asymptomatic health care personnel from reporting to work.

Transfer of Patients

Although COVID-19 patients with mild symptoms may be managed at home, the decision to remain at home should take into account the patient’s ability to adhere to isolation recommendations with the potential risk of secondary transmission to household members with compromising conditions. If a patient develops more severe COVID-19 symptoms requiring hospitalization, the HHA should inform emergency medical services and the receiving hospitals of the patient’s diagnosis prior to the transfer and should wear the proper PPE during the transfer.

Addressing Supply Shortages

CMS acknowledges the supply shortage and has directed state and federal surveyors not to cite HHAs that are unable to provide certain supplies (gowns, respirators, surgical masks and alcohol-based hand rubs) for reasons outside their control that would otherwise be required for an individualized plan of care as required by CMS regulations. However, CMS expects providers and suppliers to take actions to mitigate any resource shortages and demonstrate they are taking all appropriate steps to obtain the necessary supplies as soon as possible.

As the number of cases around the world grows, Faegre Drinker’s Coronavirus Resource Center is available to help you understand and assess the legal, regulatory and commercial implications of COVID-19.

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