Preparing for the Coronavirus: Getting Back to Basics

Although there are currently no reported cases of the coronavirus in Iowa, now is a good time for all Iowa long-term care facilities to review their policies and practices relevant to disease control and emergencies. The recent news of the death of a long-term care resident in Washington and the exposure to other residents and staff show how dire the situation can become due to the nature of long-term care facilities, as well as the underlying health conditions of the residents.

Preparation for dealing with coronavirus – or any contagious illness outbreak – is imperative.  Now is a good time for long-term care facilities to review their existing infection control policies and ensure that staff members are reminded of their obligations under such policies. The Centers for Medicare and Medicaid (“CMS”) issued a Letter to State Survey Agency Directors on February 6, 2020, which contains links to CDC guidance on infection control recommendations specific to coronavirus. The CMS Letter can be found here:  https://www.cms.gov/files/document/qso-20-09-all.pdf.

Additionally, facilities should ensure that they are compliant with the emergency preparedness requirements set forth in 42 CFR section 483.73 (https://www.ecfr.gov/cgi-bin/text-idx?SID=c4d3515068ea476b07cda7eccda2a168&mc=true&node=se42.5.483_173&rgn=div8).   These requirements include the establishment of an emergency preparedness plan with related policies and procedures, the establishment of an emergency preparedness communication plan, and a related training and testing program. CMS’s Letter to State Survey Agency Directors on the emergency preparedness requirements can be found at https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/QSO19-06-ALL.pdf. 

If you have questions about your facility’s infection control or emergency preparedness plans, please do not hesitate to contact any BrownWinick attorney in the Health Law Practice Group for assistance. For up-to-date information on the coronavirus, see the CDC website dedicated to this topic:  https://www.cdc.gov/coronavirus/2019-ncov/index.html. The American Health Care Association also has a page dedicated to providing the latest information about coronavirus to its members: https://www.ahcancal.org/facility_operations/disaster_planning/Pages/Coronavirus.aspx