​DHS COVID-19 PROVIDER GUIDANCE // OLTL

Issued: March 13, 2020

Recommendations 

Recommendation #1: Exercise and promote hygienic practices. 

The best way to prevent illness is to avoid being exposed to COVID-19. Providers should remind staff that chances of exposure can be reduced by:

• Washing hands often with soap and water for at least 20 seconds especially after being in a public place, or after blowing noses, coughing, or sneezing.
• Using a hand sanitizer that contains at least 60% alcohol if soap and water is not readily available. People should cover all surfaces of hands and rub them together until they feel dry.
• Avoiding touching eyes, nose, and mouth with unwashed hands.
• Covering mouths and noses with a tissue when coughing or sneezing or using the inside of their elbow. 
• Cleaning AND disinfecting frequently touched surfaces daily. This includes tables, doorknobs, light switches, countertops, handles, desks, phones, keyboards, toilets, faucets, and sinks.
• Staying home if sick.
  

Recommendation #2: Review your agency back-up plan and infection control procedures. 

All OLTL providers are strongly encouraged to:

• Review internal infection control protocols and emergency backup plans for events in which a provider does not have adequate staffing to meet individuals’ health and safety needs.
• Evaluate staff adherence to provider infection control protocols.
• Evaluate capacity to implement emergency backup plans in the event staffing is impacted by the COVID-19 virus.
  

Resources for Infection Control Practices: 

• Long Term Care Facility Visitation Guidance
• COVID-19 Information for At-Risk Individuals
• Strategies to Prevent the Spread of COVID-19 in Long-Term Care Facilities(LTCF) (Source: CDC)
• CMS Guidance for Home Health Agencies
• CMS Guidance on Use of Respirators for Health Care Personnel
  

Recommendation #3: Report all suspected cases of COVID-19 to DOH and OLTL and/or the participant’s CHC-MCO 

Suspected cases should always be reported first to DOH at 1-877-PA-HEALTH. For OLTL and the CHC-MCOs to be responsive to the needs related to COVID-19, timely information from the provider community is essential. If staff or a person for whom you provide services appears to be symptomatic or tests presumptively positive for COVID19, please notify the CHC-MCOs or the appropriate OLTL program area for non-CHC participants using the contact information below. In addition, providers should also contact DOH.

Recommendation #4: Contact OLTL before making any changes to your business practice whenever possible. 

It is strongly recommended that providers contact the three CHC-MCOs and OLTL before making any changes to their business practices in response to COVID-19. Examples of changes in business practices include, but are not limited to:

• Suspending services at a service location, such as an Adult Day or Structured Day Habilitation Program;
  
• Reducing or eliminating the provision of community-based activities;
• Restricting individuals’ abilities to receive services based on health status; and
• Restricting visitors in nursing facilities, Personal Care Homes or Assisted Living Residences.

OLTL is monitoring the COVID-19 situation closely and is prepared to modify expectations for compliance with contacting OLTL before making any changes to your business practice, on a case-by-case basis should emergency conditions present. By contacting the CHC-MCOs and OLTL, providers may be able to implement the most effective strategy for maintaining continuity of operations during COVID-19 outbreak. Providers may contact the CHC-MCOs and OLTL using the following contact information to notify OLTL of a proposed change in business practice and/or seek guidance related to a proposed change.

Recommendation #5 LTSS Residential Providers Should Follow State and Federally-Issued Guidance 

Nursing facilities, assisted living facilities, personal care homes, and residential habilitation providers should follow the guidance issued by DOH, CDC, and CMS, including monitoring and restricting visitors: https://www.cms.gov/files/document/qso-20- 14-nh-revised.pdf 

Recommendation #6: Document any actions that were taken and maintain evidence for why actions were taken. 

Providers should document any changes to their operations as a result of COVID-19 and maintain evidence to support why the changes were made. Doing so will help demonstrate the basis for an action in the event that the appropriateness of the action is questioned after COVID-19 is contained and operations return to normal. It will also support any changes that may need to be made to Person-Centered Service Plans and substantiate claims for services rendered in an alternative manner due to a COVID-19. 

OLTL and the CHC-MCOs will provide technical assistance with the kind of evidence that should be maintained when providers contact OLTL in accordance with Recommendation #4. In general, evidence that should be maintained includes, but is not limited to:

• Orders or notices from local authorities. Example: County Health Department A imposes a restriction on public gatherings of more than 20 people, forcing Provider B to close its adult day center. Provider B should retain the official notice from County Health Department A as evidence to support the closure.
• Correspondence and other records demonstrating inability to meet required staffing requirements. Example: Provider A’s provider-employed direct care workers (DCW) are unable to report to work due to COVID-19-related reasons. Provider A attempts to secure temporary staff from three staffing agencies, but each agency reports that they too are experiencing staff shortages. Provider A should retain copies of correspondence with each of the three staffing agencies to demonstrate that all possible efforts were made to secure enough staff
  

Recommendation #7: Stay Informed

• DOH holds daily press briefings to announce the latest efforts and updates on the commonwealth’s response to COVID-19. Providers may watch a free live stream of the daily briefing at noon here. An archive of past briefings is available here.
• As a provider of long-term services and support services, one of the most important steps you can take to stay informed about our program is subscribe to our Listservs. Important announcements, including announcements about COVID-19, are regularly sent over the Listservs.
• To subscribe to the OLTL Nursing Facility Listserv.
  
• To subscribe to the OLTL CHC Listserv.
  
• To subscribe to the OLTL Service Coordinators Listserv.
  
• To subscribe to the OLTL PA LIFE Providers Listserv.
  
• To subscribe to the OLTL Home Community Waiver Providers Listserv.
  
• To subscribe to the OLTL Nursing Home Transition Listserv.
  
• COVID-19-specific information can be found at:
• The DOH’s Coronavirus Update Page
  
• The CDC’s Coronavirus Page